Memorandum Findings of Fact and Opinion
STERRETT, Judge:
Under date of December 3, 1976 respondent issued a statutory notice of deficiency to petitioners asserting deficiencies in income tax and additions to tax as follows:
Sec. 6653(b) Calendar Year Deficiency Addition to Tax 1974 ......... $ 91,582.30 $ 45,791.15 1975 ......... 415,034.63 207,517.32
Rebecca C...
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