Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined the following deficiencies in, and additions to, the petitioners' Federal income taxes:
Addition to Tax Sec. 6653(b) Year Deficiency I.R.C. 19541 1972 ..... $12,560 $ 6,280 1973 ..... 27,805 13,902 1974 ..... 4,702 ...
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