Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
Respondent mailed petitioners a statutory notice of deficiency for taxable years 1978 and 1979, on November 4, 1981, showing the following amounts of deficiencies and additions to tax:
Sec. 6653(a)1 Year Deficiency Additions to Tax 1978 ......... $2,849 $142.45 1979 ......... 4,428 221...
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