Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined the following deficiencies and additions to tax with respect to petitioners' income taxes for the years 1964 and 1965:
Addition to Tax § 6653(a), Year Deficiency I. R. C. 1954 1964 .................. $6,722.12 $336.11 1965 ...........
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