Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in the Federal income tax of petitioner, Robert G. Oates, in the amount of $6,592.93 for the calendar year 1968. Respondent determined a deficiency in the Federal income tax of petitioner, Joan A. Snelling, in the amount of $4,557.96 and an addition to tax under section 6651(a), I.R.C. 1954,
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