STERRETT, Judge:
Respondent, by statutory notices dated September 9, 1974, determined deficiencies in petitioners' Federal income taxes as follows:
Sec. 6653(a) Docket No. Taxable year Deficiency penalty 8223-74 -------------- 1971 $40,951.80 $20,475.90 8224-74 -------------- 1972 29,155.55 ...
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