Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined the following deficiencies in and additions to the petitioners' Federal income tax:
Additions to Tax Sec. Sec. Year Deficiency 6651(a)(1)1 6653(a) 1970 ...... $ 5,245.68 $1,311.42 $262.28 1971 ...... 16,847.90 4,211.98 857...
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