Memorandum Findings of Fact and Opinion
STERRETT, Judge:
Respondent, on January 9, 1974, issued a statutory notice to James P. Keene and Prudence T. Keene in which he determined deficiencies in and additions to their Federal income taxes as follows:
Sec. 6653(b) Year Ended Deficiency Addition December 31, 1962 ...... $61,909 $30,955...
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