Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' income taxes for the calendar years 1962, 1963, 1964, 1965, and 1966 in the amounts of $31,133.28, $20,419.50, $19,405.22, $20,444.77, and $33,519.12, respectively, and additions to taxes under section 6651(a), I.R.C. 1954,
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