Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined additions to the petitioners' Federal income tax liabilities as follows:
Additions to Tax Taxable Sec. Year 6651(a)(1)1 Sec. 6653(a)2 1971 ............. $ 639.46 $ 285.98 1972 ............. -0- ...
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