Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined deficiencies and overassessments in petitioners' income tax and additions to tax under section 6653(b) as follows:
Additions to Tax Overassessment Year Amount Sec. 6653(b) 1958 .... $25,822.43 $12,911.22 ....... 1959 .... 43,709.62 21,854.81 ...
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