Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes together with additions to tax as follows:
Addition to Tax Sec. 6651(a), Sec. 6653(a), Year Deficiency I.R.C. 1954 I.R.C. 1954 1980 ..... $18,791 $939 ...
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