Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent has determined deficiencies in petitioners' Federal income taxes and additions to tax as follows:
Sec. 6653(a), I. R. C. 1954 Year Deficiency Addition to Tax 1976 ............ $2,949 $147 1977 ............ 5,106 255 1978 ............ 6,483 ...
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