MEMORANDUM FINDINGS OF FACT AND OPINION
PARKER, Judge:
Respondent determined deficiencies in Federal income tax for petitioners William C. and Elaine Gaskins and additions to tax for fraud under section 6653(b) for William C. Gaskins as follows:
Additions to Tax Taxable Year Deficiency Sec. 6653(b) 1979 .......... $16,925 $ 8,463 1980 .......... ...
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