Memorandum Findings of Facts and Opinion
SHIELDS, Judge:
Respondent determined deficiencies in and additions to petitioners' Federal income tax as follows:
Additions to Tax Year Deficiency Section 6653(a)1 1977 ........ $140,659.72 $7,032.98 1978 ........ 95,853.94 4,792.69 1979 ........ 165,546...
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