Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes and additions to tax as follows:
Addition to Tax ----------------------------- Sec. 6653(b), Sec. 6653(a), Year Deficiency I.R.C. 1954 I.R.C. 1954 1976 .... $ 96,493...
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