Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By letter dated December 22, 1978, respondent determined deficiencies in petitioners' income taxes and additions to tax under section 6653(a), I.R.C. of 1954, as follows:
I. R. C. Year Deficiency Sec. 6653(a) 1974 ........ $32,816.95 $1,640.84 1975 ........ 20,155.56 1,007.77 1976 ........ 21,038.75 1,051.93
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