Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined the following deficiencies in petitioners' joint Federal income taxes:
Taxable Year Ended December 31 Deficiency 1970 ................ $19,523.00 1971 ................ 47,113.50 1972 ................ 26,557.00
In addition, respondent has determined an addition to tax under section 6653(b)
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