Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes and additions to tax as follows:
Addition Year Deficiency Sec. 6653(a)1 1975 ....... $1,011.00 $ 50.55 1976 ....... 2,134.00 106.70
At trial, the Court granted respondent's motion to dismiss the petition for lack of...
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