Memorandum Opinion
CLAPP, Judge:
Respondent determined deficiencies in and additions to petitioners' Federal income taxes as follows:
Additions to tax Year Deficiency Sec. 6653(b) Sec. 6654 1978 .................... $74,195 $37,098 -- 1979 .................... 50,323 25,162 $913 1980 .............
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