Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent, under the authority of section 6653(b),1 determined additions to petitioners' income tax for the taxable years 1963, 1964, and 1965 of $1,071.11,* $492.50, and $757.50, respectively. The sole issue to be decided is whether petitioners possessed the fraudulent intent necessary to warrant the asserted additions to tax.
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