Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
Respondent determined deficiencies in petitioners' income tax and addition thereto for the years and in the amounts as follows:
Addition to Tax § 6651(a), Year Deficiency I. R. C. 1954 1960 .......... $ 3,934.24 ..... 1961 .......... 11,833.99 ..... 1962 .......... 22...
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