Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent 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 1977 ............ $ 270 $ 13.50 1978 ............ 4,280 214.00 1979 ............ 4,313 215...
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