Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
Prior to the issuance of the statutory notice, petitioners agreed to understatements of taxable income for 1973 of $64,503.61 and for 1974 $91,194.51. These agreed understatements resulted in understatements of income tax in the amounts of $21,337.71 and $46,082.74 for the two years. The 1973 deficiency was paid in full and all but $3,000 of the 1974 deficiency was paid, this amount resulting from...
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