Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent detrmined the following deficiencies in and additions to petitioners' income tax for the years and in the amounts as follows:
Addition to I. R. C. Calendar Tax Sec. 1954 Sec. Year Deficiency 6651(a) 6653(a)1 1972 .... $ 127.58 $ 31.90 $227.31 1973 .... 362.60 ...
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