Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined deficiencies in petitioners' Federal income tax for the taxable years 1974, 1975, 1976, and 1977 in the amounts of $12,199.20, $9,729.74, $17,965.87, and $24,786.71, respectively. The Commissioner also determined that additions to tax under section 6653(b)
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