Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined deficiencies in petitioners' 1973 Federal income taxes, and additions to tax, as follows:
Additions to Tax, I. R. C. 1954 Year Deficiency Sec. 6653(a) Sec. 6651(a) 1973 .... $12,130.16 $639.10 $275.50
Due to concessions, the primary issue still in dispute...
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