Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined deficiencies in and additions to petitioners' Federal income tax as follows:
Additions to Tax, IRC 1954 Year Deficiency Section 6653 (a) 1977........ $34,472.88 $ 0.00 1979........ 37,338.00 $1,867.00
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