Memorandum Findings of Fact and Opinion
WILBUR, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes as follows:
Additions to Tax Under Sections Year Deficiency 6651(a) 6653(a)1 1973 ....... $21,396 $ 1,137 ....... 1974 ....... 59,149 4,977 $ 3,289 1975 ....... 58,849 11,770 3,777
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