Memorandum Findings of Fact and Opinion
STERRETT, Judge:
Respondent, on December 13, 1974, issued a statutory notice in which he determined a deficiency in petitioners' Federal income tax for their taxable year ended December 31, 1970 in the amount of $19,836.46 and an addition to tax under section 6653(b), I.R.C. 1954 for fraud in the amount of $9,918.23. Respondent has conceded that the addition to tax was unwarranted. The following issues remain for our...
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