Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By notice of deficiency dated September 19, 1980 respondent determined the following deficiencies in, and additions to, petitioners' Federal income taxes:
Addition to tax under Year Deficiency sec. 6651(a) 1976 ........... $2,581 $494 1977 ........... 2,203 298 1978 ........... 2,416 ....
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