Memorandum Opinion
GERBER, Judge:
Respondent, in a statutory notice of deficiency dated April 13, 1984, determined deficiencies in income tax and additions to tax for petitioners' 1976, 1977 and 1978 taxable years, as follows:
Addition to Tax Taxable Year Income Tax Section 6653(b)1 1976 $10,876.31 ...
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