Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined a deficiency in petitioners' income tax for the year 1973 in the amount of $1,258.98. Petitioners challenged the propriety of the entire amount of this deficiency in their petition herein and by way of answer respondent affirmatively pled that in addition petitioners are liable for an addition to tax under section 6653(a), I.R.C. 1954.
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