Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies and additions to petitioners' Federal income tax as follows:
Sec. 6653(a)1 Year Deficiency Addition to Tax 1979 ............ $45,148 $2,258 1980 ............ 31,405 1,570
All issues relating to the notice of deficiency...
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