Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in the income taxes of petitioners Harold A. Hobson, Jr. and Joan E. Hobson for the calendar years 1972 and 1973 in the amounts of $14,433.89 and $11,021.32, respectively, and an addition to tax under section 6653(a), I.R.C. 1954,
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