Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined the following deficiencies in petitioners' Federal income taxes:
Addition to Tax Year Deficiency Sec. 6653(a)1 1970 .......... $5,779.84 $288.99 1970 .......... 7,302.77 365.14 1972 .......... 940.89 47.05
Because of concessions...
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