Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined a deficiency in the Federal income tax of petitioner and his wife, Peggy Rodgers, for the taxable year 1974 in the amount of $2,163.28. The Commissioner also determined an addition to tax for the taxable year 1974 pursuant to section 6653(a), Internal Revenue Code of 1954,
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