Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies and additions to tax in petitioners' Federal income tax as follows:
Additions to Tax Year Deficiency Sec. 6651(a)(1)1 Sec. 6651(a)(2) 1978 ............ $17,832.99 $4,458.25 $378.56 1979 ............ 1,973...
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