Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
In the statutory notice of deficiency, respondent determined the following deficiencies in and additions to petitioners' income tax:
Additions to tax sec. 6653(b), Year Deficiency I. R. C. 1954 1971 ............. $19,948.73 $ 9,974.37 1972 ............. 47,672.16 23,836.08
The...
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