Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in the Federal income taxes of petitioners and an addition to tax as follows:
Addition to Tax Year Deficiency § 6654, IRC 1954 1961 ........ $ 5,138.42 ....... 1962 ........ 3,024.40 ....... 1963 ........ 39,972.97 ....... 1964 ........ 67,709...
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