OPINION
RAUM, Judge:
The Commissioner determined deficiencies in income tax and additions to tax against petitioners, Webster Lair and Pearl Lair, husband and wife, for the calendar years 1984 and 1985 in the following amounts:
Year Deficiency Sec. 6653(a)(1)1 Sec. 6653(a)(2) Sec. 6661 1984 $21,480...
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