Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes and additions to tax as follows:
Additions to Taxable Tax I.R.C. Year Deficiency Sec. 6653(b) 1973 ........ $ 57,581.12 $28,790.56 1974 ........ 90,985.78 45,492...
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