Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined a deficiency of $25,269.87 in the income tax of petitioners for the year 1959 and an addition to tax in the amount of $1,263.49. The principal issue for decision is whether petitioners understated their taxable income for the year 1959 and, if so, in what amount. A secondary issue is whether petitioners are liable for an addition to tax under the provisions of section 6653(a).
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