GERBER, Judge:
Respondent, in a statutory notice of deficiency dated May 8, 1986, determined deficiencies and additions to petitioners' 1981 and 1982 income taxes as follows:
Additions to tax Year Deficiency Sec. 6653(b)1 Sec. 6661 1981 $12,418 $6,209 --- 1982 ...
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