Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By notice of deficiency dated September 25, 1975, respondent determined deficiencies in petitioners' Federal income taxes. Subsequently concessions were made with the consequence that the deficiencies remaining in issue are as follows:
Addition to tax Taxable year pursuant to ended Dec. 31, Deficiency sec. 6653(b) 1971...
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