Memorandum Findings of Fact and Opinion
NIMS, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes and additions to tax as follows:
Additions to tax Year Deficiency Sec. 6653(b) Sec. 66541 19752 ......... $7,731.22 $3,865.61 $332.02 1976........ 3,669.70 1,834.85 1977...
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