Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined the following deficiencies in and additions to petitioners' Federal income taxes:
Addition to tax Year Deficiency Sec. 6661 1980 ................ $28,621.62 -- 1981 ................ 27,186.00 -- 1982 ................ 550.70 -- 1983 .........
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