Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined deficiencies in and additions to petitioners' Federal income taxes as follows:
Additions to Tax Sec. Sec. Docket No. Year Deficiency 6653(b) 6654(a)2 20451-82 1971 $3,194 $1,597 $102 1972 5,938 ...
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