Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By letter dated July 22, 1977, respondent determined deficiencies and additions to petitioners' Federal income taxes as follows:
Taxable Sec. Sec. Year Ended Deficiency 6651(a) 6653(a) December 31, 1973 .. $30,683.00 $ -0- $1,534.15 December 31, 1974 .. 796.00 119.40 39.80
After concessions
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