Memorandum Findings of Fact and Opinion
PARKER, Judge:
Respondent determined deficiencies in petitioners' Federal income tax and additions to tax as follows:
Year Deficiency Addition to Tax Sec. 6653(b) 1974 .............................. $ 5,164.80 $ 2,582.40 1975 .............................. 1,941.00 970.50 1976 ................................
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