Memorandum Findings of Fact and Opinion
SWIFT, Judge:
Respondent determined deficiencies and additions to tax in petitioners' joint Federal income tax, as follows:
Additions to Tax, Secs.1 Year Deficiency 6651 6653(a)(1) 6653(a)(2) 6661 1983 ................. $95,153 $33,099 ...
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