Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in and additions to petitioners' Federal income tax in the following amounts:
Addition to Tax Year Deficiency Sec. 6653(a)...1 19722 .............. $19,189.24 $ 964.46 1973 ............... 93,976.57 4,698.83
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