Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined a deficiency of $8,730.98 in petitioners' 1971 Federal income tax and imposed additions to tax as follows:
Additions to Tax Taxable Year Sec. 6653(b)1 1971 ............. $ 4,365.49 1972 ............. 14,404.31 1973 ............. 25,812.19
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