Memorandum Findings of Fact and Opinion
NIMS, Chief Judge:
Respondent determined the following deficiencies and additions to petitioners' Federal income tax:
Additions to Tax Year Deficiency Section 6659 1980 ............... $23,011.00 -- 1981 ............... 8,667.00 $2,600.00 1982 ............... 5,612.96 1,683.89
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