Memorandum Opinion
FAY, Judge:
Respondent determined deficiencies in and an addition to petitioners' Federal income tax as follows:
Sec 6651(a)1 Year Deficiency Addition to Tax _______________________________________________________ 1976 .......... $ 22,890.48 ........ 1977 .......... 77,788.20 ........ 1978 .......... 109,942.17 $21...
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