Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes and additions to tax as follows:
Addition to Tax Year Deficiency Sec. 6651(a)1 1973 .......... $1,571.47 $348.37 1974 .......... 2,654.00 635.50
The three issues presented for our decision are: (1) whether...
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