Memorandum Findings of Fact and Opinion
WRIGHT, Judge:
By separate notices of deficiency dated February 29, 1984, and December 26, 1984, respondent determined deficiencies in petitioners Melvin and June Cochran's income tax and additions to tax for taxable years 1980 and 1981 as follows:
Additions to Tax Taxable Year Deficiency Sec. 6653...
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