Memorandum Findings of Fact and Opinion
STERRETT, Judge:
Respondent, on November 10, 1977, issued a statutory notice to petitioners in which he determined a deficiency in Federal income tax for their taxable year 1974 in the amount of $3,599.95 and additions to tax under sections 6651(a) and 6653(a), I.R.C. 1954, of $539.99 and $184.73, respectively. After concessions by both parties the remaining issues before us are: (1) whether petitioners understated...
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