Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes and additions to the tax for fraud as follows:
Addition Year Deficiency Sec. 6653(b) 1 1971 ......... $3,932.40 $1,966.20 1972 ......... 6,091.95 3,045.98
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