Memorandum Findings of Fact and Opinion
JACOBS, Judge:
Respondent determined the following deficiencies in, and additions to, petitioners' Federal income taxes:
Year Deficiency Section 6653(a) 1976 .......... $7,443.00 $372.15 1977 .......... $8,745.80 $437.28 1978 .......... $8,805.20 $440.26
After concessions, the sole issue for decision is whether the corporation...
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