SCOTT, Judge:
Respondent determined deficiencies in petitioners' Federal income tax for the taxable years 1973 and 1974 in the amounts of $7,008.26 and $4,314.75, respectively, and determined additions to tax for those years under section 6653(a), I.R.C. 1954,
Some of the issues raised by the pleadings have been disposed of by agreement of the parties leaving for our decision:
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