Memorandum Findings of Fact and Opinion
STERRETT, Judge:
Respondent, in his notice of deficiency dated July 31, 1978, determined deficiencies in petitioners' 1975 and 1976 Federal income taxes and additions to tax under section 6653(a), I.R.C. 1954, as follows:
Addition to tax under Year Deficiency sec. 6653(a) 1975 ........... $2,151 $108 1976 ........... 5,218 ...
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