Memorandum Findings of Fact and Opinion
IRWIN, Judge:
Respondent determined deficiencies in and additions to petitioners' income taxes as follows:
Addition to the Tax (I. R. C. Year Deficiency § 6653(a))1 1974 ......... $4,019.96 $201.00 1975 ......... 3,736.45 186.82
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