SELLERS v. COMMISSIONER

Memorandum Findings of Fact and Opinion

BRUCE, Judge:

In these cases, which were consolidated for trial, briefing, and opinion pursuant to a joint motion of the parties, respondent determined deficiencies in, and additions to, Federal income tax, and transferee liability of the petitioners, for the years and in the amounts as follows:

                            Additions to Tax  
  Year    Deficiency    Sec. 6651(a) ...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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