Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in and an addition to petitioners' Federal income tax as follows:
Sec. 6653(a)1 Year Deficiency Addition to Tax 1970 ........... $ 421.02 ......... 1971 ........... 4,785.35 ......... 1972 ........
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