Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined deficiencies in petitioners' income taxes for the taxable year 1964 as follows:
Addition to tax (Sec. 6651(a) Income tax I.R.C. 1954)2 Richard A. Zaun ... $64,674.76 ....... Lois Jean Zaun .... 6,781.53 $1,695.38...
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