Memorandum Opinion
WILBUR, Judge:
Respondent determined the following deficiencies and additions to tax with respect to petitioners' Federal income taxes for 1975 and 1976:
Addition to Tax Year Deficiency Sec. 6653(b)1 1975 ............. $4,194.96 $2,097.48 1976 ............. 5,079.68 2,539.84
This case is before us upon respondent's...
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