Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent deficiencies in petitioners' income tax for the calendar years 1969, 1970, 1971 and 1972 in the respective amounts of $4,168.67, $3,015.23, $43,253.02, and $11,131.09, and additions to tax under section 6653(b), I.R.C. 1954,
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