Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined deficiencies in petitioners' income taxes of $2,385.62 for 1964, $1,424.21 for 1967, and $2,226.16 for 1968. Respondent also determined negligence penalties of $71.21 for 1967 and $111.31 for 1968 under section 6653 (a).
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