Memorandum Opinion
RAUM, Judge:
The Commissioner determined deficiencies in income tax and additions to tax against Martin and Jerrilyn Brody (petitioners) for the taxable years 1977, 1978, and 1979, as follows:
Year Amount Section 6653(a) 1977 ........... $26,738.00 $1,336.90 1978 ........... 36,161.40 1,807.57 1979 ........... 174.32 8.72
As part of the...
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