Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined the following deficiencies in and additions to the petitioners' Federal income tax:
Date Addition Taxable Statutory to Tax Year Notice Mailed Deficiency Sec. 6653(b)1 1972 4/13/79 $82,015 $41,007.50 1974 9/14/79 72...
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