Memorandum Findings of Fact and Opinion
KöRNER, Judge:
Respondent determined deficiencies in income tax and additions to tax against petitioners for the years and in the amounts as follows:
Calendar Additions to Tax Years Deficiency Sec. 6651(a)1 1973........ $74,821.69 $17,572.35 1974........ 22,851.67 3,167.57
Although a number of...
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