Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes and additions to tax as follows:
Addition to Tax Year Deficiency Sec. 6653(a)1 1975 ........... $1,685.43 $84.27 1976 ........... 641.72 32.09
After concessions by both parties, the only issue remaining is whether...
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