Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By notice of deficiency dated February 20, 1979, respondent determined deficiencies in and additions to petitioners' Federal income taxes as follows:
Taxable Addition Year Ended to Tax Under Dec. 31, Deficiency Sec. 6653(a) 1974 ............ $16,856.76 $842.84 1975 ............ 6,175.40 308.77
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