OPINION
SWIFT, Judge:
In a timely statutory notice of deficiency, respondent determined deficiencies in petitioners' Federal income tax liabilities and additions to tax for 1978, 1979, and 1980, as follows:
Addition to tax Year Deficiency sec. 6653(a)1 1978 $245,706 $12,285.30 1979 302,293 15,114.65 1980 239,449 ...
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