Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined deficiencies in petitioners' Federal income taxes as follows:
Taxable Section 6651(a)1 year Income tax penalty 1972 .......... $35,990.66 -0- 1973 .......... 3,317.67 $829.42
Concessions having been made, the following issues remain for our decision: (1...
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