Memorandum Findings of Fact and Opinion
HOYT, Judge:
For the years 1963 and 1964 respondent has determined deficiencies in Federal income taxes and additions to tax under section 6653(a)
Year Tax Sec. 6653(a) 1963 ......... $9,149.89 $457.49 1964 ......... 5,806.85 290.34
The two issues remaining for our decision are whether petitioners incurred certain...
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