Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined the following deficiencies in Federal income tax and additions to tax against petitioners:
Deficiency Addition to Tax Taxable Year in Tax Sec. 6643(a)1 1975 ...... $1,533.83 $76.69 1976 ...... 1,345.40 67.27 1977 ...... 1,602.00 80.10
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