Memorandum Findings of Fact and Opinion
IRWIN, Judge:
By letter dated December 3, 1976 respondent determined deficiencies and additions to petitioners' Federal income taxes as follows:
Addition to Tax Year Deficiency Section 6653(a)1 1972 .......... $1,666.09 $83.30 1973 .......... 1,643.03 82.15 1974 .......... 1,763.42 ...
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