Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined deficiencies in petitioners' Federal income tax and additions to tax as follows:
Addition to Tax Sec. 6653(a), Year Deficiency I.R.C. 1954 1977 $ 8,318 $ 416 1978 25,756 1,288
The following issues are presented for decision:
1. Whether petitioners are...
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