Memorandum Opinion
WILBUR, Judge:
Respondent determined the following deficiencies and additions to tax:
Year Deficiency Addition to tax Sec. 6653(b)1 1979 $ 6,377 $ 3,189 1980 28,491 14,246 1981 36,507 18,254
This matter is before us on the petitioners' motions to suppress evidence and to shift the burden of proof, which we...
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