Memorandum Findings of Fact and Opinion
SWIFT, Judge:
Respondent determined deficiencies in and additions to tax with respect to petitioners' joint Federal income taxes for 1979 through 1983 as follows:
Additions to Tax Year Deficiency Sec. 6651(a)(1) 1979 ............. $ 72,185 $18,046 1980 ............. 10,689 2,672 1981 ..........
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