Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined the following deficiencies and additions to tax with respect to petitioners' income taxes:
Addition to Tax, Sec. 6653(a), Year Deficiency I. R. C. 1954 1973 ............ $113,269 $ 5,663 1974 ............ 145,549 8...
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