Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined income tax deficiencies of $3,626 and $4,454 for the taxable years ended December 31, 1976, and December 31, 1977, respectively, against petitioners Eugene and Lorraine Feistman. The Commissioner also determined that petitioners were liable for additions to tax under section 6653(a), I.R.C. 1954, of $181 for 1976 and $223 for 1977, respectively. The issues for decision are:...
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