Memorandum Findings of Fact and Opinion
PARKER, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for the taxable year 1977 in the amount of $16,817.86 and an addition to tax under section 6651(a) in the amount of $4,204.47. Subsequently, by amendment to his answer, respondent increased the deficiency to $246,653 (an increase of $229,835.14) and increased the late filing addition to $61,663 (an increase of $57,458.53). This increased...
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