Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined deficiencies in and additions to petitioners' Federal income taxes as follows:
Additions to Tax Year Deficiency Section 6653(a)1 1979 ....... $134,320.00 $6,716.01 1980 ....... 128,941.96 6,447.10 1981 ....... 19,475.94 973.80
After...
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