Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for the calendar years 1979 and 1980 in the amounts of $186,670 and $295,318, respectively. In an amendment to answer, respondent alleged that petitioners were liable for additions to tax under section 6653(a) in the amounts of $9,333.50 and $14,765.90 for the years 1979 and 1980, respectively...
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