Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined the following deficiencies in petitioners' Federal income taxes:
Additions to tax Section Year Deficiency 6653(a) 1972 ............. $ 6,338.00 -0- 1973 ............. 17,056.00 $853.00 1974 ............. 25,911.00 -0-
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