Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' income tax and additions to tax for the years and in the amounts as follows:
Additions to Tax Calendar Deficiency in I.R.C. 1954 Year Income Tax Section 6653(a) 1977 ........... $6,928 $346.40 1978 ........... 3,200 160.00 1979
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