Memorandum Findings of Fact and Opinion
COHEN, Judge:
In a statutory notice sent April 7, 1988, respondent determined deficiencies in and additions to petitioners' Federal income taxes as follows:
Additions to Tax Year Deficiency Sec. 6653(b) 1979 ............ $ 9,568.50 $ 4,784.25 1980 ............ 23,965...
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