Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By notice of deficiency dated August 18, 1980, respondent determined a deficiency in and additions to petitioners' Federal income taxes for the taxable year 1976 as follows:
Addition to tax Addition to tax pursuant to pursuant to Deficiency sec. 6651(a) sec. 6653(a) $8,656.00 ....... $1,298.40 $464.05
The...
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