HOFFMAN v. COMMISSIONER

Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent, in a statutory notice of deficiency dated May 25, 1984, determined deficiencies and additions to petitioners' 1980 and 1981 income taxes as follows:

                                      Sec. 6653(b)1
Year                    Deficiency   Addition to Tax

1980 .................   $9,954.67       $ 5,411.34
1981 ........

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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