Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in and additions to petitioners' Federal income tax as follows:
Additions to Tax Under I.R.C. Sections Year Deficiency 6651(a)(1)1 6653(a) 6653(a)(1) 6661 1980 ..................... $29,447 $2,944...
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