Memorandum Findings of Fact and Opinion
STERRETT, Judge:
In his notice of deficiency dated May 28, 1981, respondent determined the following deficiencies in and additions to petitioners' Federal income taxes:
Addition to tax pursuant to Year Deficiency sec. 6653(b) 1974.......... $21,235.96 $10,617.98 1975.......... 7,277.31 3,638.66 1976...
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