Memorandum Opinion
WILBUR, Judge:
Respondent determined the following deficiencies and additions to tax:
Additions to Tax Sec. Sec. Year Deficiency 6653(a)1 6651(a) 1977.... $ 96,533 $ 4,924 $ 24,134 1978.... 305,062 15,253 ......
This matter is before us on petitioners' motions...
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