Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined deficiencies in petitioners' income taxes and additions to tax for 1982 and 1983 as follows:
Sec. 66611 Year Deficiency Additions to Tax 1982 .......... $ 7,915.21 $1,979.00 1983 .......... 12,709.00 3,177.00
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