Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
Respondent determined deficiencies in. Beatrice and Matthew Ianniello's Federal income tax and additions to tax as follows:
Addition to Tax Year Deficiency Sec. 6653(b)1 1981 ............ $131,878.50 $65,939.25
Mrs. Ianniello, petitioner, filed a petition...
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