Memorandum Findings of Fact and Opinion
QUEALY, Judge:
Respondent determined deficiencies in the Federal income taxes and additions to the tax due from the petitioners as follows:
Addition to the tax, section Year Deficiency 6653(b)1 1965 ..... $111,123.57 $55,561.79 1966 ..... 5,598.89 2,799.45
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