Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined the following deficiencies in petitioners' Federal income taxes and additions to tax for 1974 and 1975:
Donald E. Spencer Additions to Tax Sec. 6651(a) Sec. 6653(a) Year Deficiency I. R. C. 1954 I. R. C. 1954 1974 .... $2,964 $741 $148 1975...
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