Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined the following income tax deficiencies and additions to tax in these consolidated cases:
Additions to Tax, I.R.C. 1954 Name Docket No. Year Deficiency Sec.6651(a) Sec. 6653(a) William H. Willard ......... 2164-80 1976 $ 6,889.79 $1,445.37 and Judith T. Willard...
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