Memorandum Findings of Fact and Opinion
HAMBLEN, Judge:
Respondent determined deficiencies in petitioners' Federal income tax and additions to tax as follows:
Additions to Tax Taxable Year Ended Deficiency Section 6653(a)1 December 31, 1979 $15,671.00 $ 938.70 December 31, 1980 36,136.00 1,974.15
After concessions...
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