Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in and additions to petitioners' Federal income tax for the taxable years 1976 and 1977 as follows:
Addition to tax Year Deficiency Sec. 6653(a)1 1976 ......... $ 692.23 $34.61 1977 ......... 1,409.64 70.48
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