Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
In docket No. 44931-85, respondent by notice of deficiency dated October 10, 1985, determined the following deficiencies in and additions to petitioners' Federal income tax:
Additions to Tax Year Deficiency Sec. 6653(a) 1978 ........... $ 45,496.08 $2,274.80 1979 ........... 167...
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