Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies in petitioners' income taxes and additions to tax for 1975 and 1976 in the following amounts:
Additions to Tax Sec. Sec. Year Deficiencies 6651(a)1 6653(a) 1975 ...... $11,828.16 $449.87 $594.41 1976 .....
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