Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in the Federal income tax and additions to tax for petitioners for the calendar years 1967 and 1968 as follows:
Addition to Tax Under Sec. 6653(a) Year Deficiency I. R. C. 1954 1967 ........... $17,188 $859 1968 ........... 16,480 824
Concessions...
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