Memorandum Findings of Fact and Opinion
STERRETT, Judge:
In a joint statutory notice of deficiency dated April 12, 1978 respondent determined deficiencies in income taxes and additions thereto as follows:
Addition to Tax Year Deficiency Sec. 6653(b) Total 1971 ...... $11,012 $ 5,506 $16,518 1972 ...... 18,548 ...
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