Memorandum Findings of Fact and Opinion
NIMS, Judge:
Respondent determined the following deficiencies in petitioners' federal income tax:
Sec. 6653(a)1 Docket No. Tax year Deficiency Addition to Tax 11111-79 1975 $477,213 none 15083-80 1976 264,288 $13,214 15083-80 1977 51,737 2,587
The parties...
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