Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined a deficiency in the amount of $47,054.74 in petitioners' 1972 Federal income tax. By an amendment to his answer, respondent alleged that the deficiency was actually $65,824.44 and that a $3,291.22 addition to tax is due under section 6653(a).
Respondent has conceded one issue, and the issues remaining for decision are as follows:
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