Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent issued a notice of deficiency to petitioners for the years 1974 and 1975, dated August 14, 1985, determining deficiencies in their income tax in the amount of $10,976 for the year 1974 and $23,753 for the year 1975, and additions to tax under section 6653(a) of the Internal Revenue Code for each of those years in the amounts of $549 and $1,188, respectively.
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