Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined the following deficiencies in, and additions to, the petitioners' Federal income taxes:
Additions To Tax Sec. 6653(a) Year Deficiency I. R. C. 19541 1973 ........ $4,536.54 — 1974 ........ 4,357.24 — 1975 .......
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