Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in petitioners' Federal income tax and additions to tax as follows:
Income Additions to Tax Tax Section Year Deficiencies 6653(b)...1 1978 $3,480.70 $1,740.35 1979 7,669.90 3,834.95 1980 7,956.90 3,978.45
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