Memorandum Findings of Fact and Opinion
KORNER, Judge:
In his notice of deficiency, respondent determined the following deficiencies and additions to tax in petitioners' Federal income tax:
Additions to Tax, Sections1 Year Deficiency 6653(b) 6653(b)(1) 6653(b)(2) 6661 1980 ......... $15,353...
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