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 1978 ........ $1,872.00 $93.60 1979 ........ 1,130.00 56.50
At issue are (1) whether petitioners are entitled to...
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