BIAGIOTTI v. COMMISSIONER

Memorandum Findings of Fact and Opinion

WHITAKER, Judge:

On February 25, 1983, respondent issued a statutory notice of deficiency to petitioners determining the following deficiencies and additions to tax for the taxable years 1976 through 1980:

                                          Addition to Tax
   Year               Deficiencies        Section 6653(a)1

  1976 .................

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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