Memorandum Findings of Fact and Opinion
NIMS, Chief Judge:
Respondent determined deficiencies in and additions to petitioners' Federal income tax as follows:
Additions to tax—Sections --------------------------------- Year Deficiency 6653(a)(1) 6653(a)(2) 6661(a) 1984 $34,183 $1,709 * $ 8,546 1985 46,766 ...
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