Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent determined a deficiency of $1,021.51 in petitioners' Federal income tax for the taxable year 1974. Respondent has also assessed additions to tax of $594.88 and $958.76 for the years 1973 and 1974, respectively, under the civil fraud provision, section 6653(b).
(1) Whether petitioners received payment from an insurance...
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