ATKINS, Judge:
The respondent determined a deficiency in income tax against the petitioners for the taxable year 1965 in the amount of $21,438.75 and additions to tax under section 6651 (a) of the Internal Revenue Code of 1954 in the amount of $5,359.68 and under section 6653 (a) of the Code in the amount of $1,291.84. The issues presented
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