Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined deficiencies in petitioners' Federal income tax and additions to tax for the fraud penalty (section 6653(b)) as follows:
Additions Year Deficiency to Tax 1967 ............. $11,595.86 $5,797.93 1968 ............. 12,142.58 6,071.29
The issues to be decided are:
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