Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies and penalty in petitioners' income tax for the years 1957 to 1964, inclusive, as follows:
Penalty Year Deficiency Sec. 6651(a) 1957 ............. $ 833.40 ..... 1958 ............. 1,679.38 ..... 1959 ............. 1,241.56 ..... 1960 ............. 4,327.01...
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