Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent determined deficiencies in and additions to petitioners' joint Federal income taxes as follows:
Addition to Tax Year Deficiency Section 6653(a)1 1978 ................ $ 79,372.00 $3,968.60 1979 ................ $108,342.00 $5,417.10
Petitioners...
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