Memorandum Opinion
KÖRNER, Judge:
Respondent determined deficiencies in income tax and additions to tax against petitioners as follows:
Addition to Tax Year Deficiency Tax Section Ended 6653(a) I.R.C.1 Dec. 31, 1976 ..... $2,155 $107.75 Dec. 31, 1977 ..... 755 37.75
After concessions...
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