Memorandum Findings of Facts and Opinion
STERRETT, Judge:
Respondent, on April 9, 1975, issued a statutory notice in which he determined deficiencies in, and additions to, petitioners' Federal income tax as follows:
§ 6653(a) Year Ended Tax Addition to Tax 12/31/70 .... $149,239.82 $7,461.99 12/31/71 .... 41,336.93 2,066.85 12/31/72 .... 146,705.62...
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