Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined the following deficiencies in petitioners' Federal income taxes and additions to tax:
Addition to Tax Year Deficiency Sec. 6653(a)1 1975 $ 643.00 $32.15 1977 2,100.00 105.00 1978 3,871.00 193.55
The issues presented for decision are:
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