Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined deficiencies in petitioners' Federal income tax and additions to tax for 1960 and 1961 as follows:
Additions to Tax (Sec. 6653(a), Year Deficiency I.R.C. 1954) 1960 ........ $3,191.47 $159.57 1961 ........ 2,444.70 122.24
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