Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By notice of deficiency dated September 27, 1979, respondent determined deficiencies in and additions to petitioners' Federal income taxes as follows:
Addition Addition pursuant pursuant Taxable to sec. to sec. Year Deficiency 6651(a)(1) 6653(a) 1975 ........ $2,682 .... ...
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