Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in the income tax of petitioner Martin C. Planken for the calendar years 1955 and 1956 in the respective amounts of $487 and $513, and in petitioners' income tax for the calendar year 1957 in the amount of $476.84. Respondent also determined additions to the tax under section 6653(b)
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