Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in and additions to petitioners' Federal income tax as follows:
Sec. 6653(a)1 Year Deficiency Addition to Tax 1979 ............. $3,283 $164 1980 ............. 3,387 169 1981 ............. 8,836 192
The issues are (1) whether...
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