Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes and additions to tax in the following amounts:
Sec. 6653(a)1 Year Deficiency Addition 1975 ......... $6,613.67 $330.68 1976 ......... 4,863.94 243.19
After concessions by the parties, the issues for decision...
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