Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
In a notice of deficiency mailed to petitioners on May 22, 1987, respondent determined the following deficiencies in and additions to petitioners' Federal income taxes:
Addition to Tax1 Year Deficiency Section 6653(b) 1977 ....... $11,243.04 $5,621.52 1978 ....... $18,930.22...
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