Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in and additions to petitioners' Federal income tax as follows:
Additions to Tax Under Years Deficiencies Section 6651(a)(1) 1980 ................. $1,090.00 $286.18 1981 ................. 1,850.60 75.63
After concessions by both parties...
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