Memorandum Findings of Fact and Opinion
QUEALY, Judge:
For the years 1961 and 1963, respondent determined deficiencies in the Federal income tax of petitioners and additions thereto as follows:
Kellner, Dkt. Addition to Tax No. 4005-68 Deficiency Section 6653(a) ------------- ---------- --------------- 1961 .......... $52,569.35 $2,628.47 1963 ............
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