Memorandum Opinion
DRENNEN, Judge:
Respondent determined deficiencies in and additions to the Federal income taxes of Maxwell J. and Naomi Estroff for the taxable years 1974 and 1975 as follows:
Addition to tax1 Year Deficiency sec. 6653(a) 1974 ........... $62,568.06 $3,128.40 1975 ........... 13,030.35 651.52
After concessions...
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