Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined the following deficiencies in petitioners' Federal income taxes and additions to tax under section 6651(a):
Addition to Tax Year Deficiency (Sec. 6651(a)) 1973 ....... $19,341 $-0- 1974 ....... 4,771 239
The issues for decision are...
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