Memorandum Opinion
KÖNER, Judge:
For the calendar years 1975 and 1976, respondent determined deficiencies in income tax and additions to tax against petitioners as follows:
Deficiency in Income Additions to Tax Years Tax Section 6653(a)1 1975 ....... $39,110 $1,956 1976 ....... 14,322 716
In their petition herein, as twice...
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