Memorandum Findings of Fact and Opinion
CLAPP, Judge:
In these consolidated cases, respondent determined deficiencies and additions to tax in each petitioner's Federal income tax as follows:
Richard Downey Additions to Tax Sec. Sec. Year Deficiency 6653(b)1 6654 1972 ...... $1,380.82 $690.41 $11.07 1973...
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