Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
Respondent determined the following deficiencies and additions to petitioners' Federal income taxes:
Addition to Tax Sec. 6653(a), Year Tax I. R. C. 1954 1971 .......... $ 797.96 $39.90 1972 .......... 1,449.77 72.49
After certain concessions, the issues are whether...
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