Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' income taxes and additions to tax for the calendar years 1961, 1962 and 1963 in the following amounts:
Sec. 6653(a) Year Deficiency1 Addition to tax 1961 ............ $ 2,694.16 $ 134.71...
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