Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in petitioners' income tax and additions to tax for the years and in the amounts as follows:
Addition to Taxable Year Tax under Ended Dec. 31, Deficiency Sec. 6653(a)1 1969 $12,465.82 $623.29 1970 5,570.62 278.53
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