Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined the following deficiencies and additions to tax against the petitioners:
Addition to tax Taxable Sec. 6651(a) year Deficiency I. R. C. 1954 1960 ....................... $2,413.78 $482.76 1961 ....................... 4,545.58 ...
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