Memorandum Opinion
CLAPP, Judge:
Respondent determined the following deficiencies in and increased interest on the underpayment of petitioner and her husband's Federal income taxes:
Increased Interest Year Deficiency Sec. 6621(c) 1977 ............... $ 77,799 * 1978 ............... 179,581 * 1979 ............... 97...
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