Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Respondent determined deficiencies in the income tax of petitioners and additions to tax as follows:
Addition to tax Sec. 6651 (a), Year Deficiency I. R. C. 19541 1965 ......... $6,183.19 ...... 1966 ......... 3,591.31 $425.30
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