Memorandum Findings of Fact and Opinion
SWIFT, Judge:
By statutory notice of deficiency dated April 14, 1980, respondent determined deficiencies in petitioners' Federal income tax liabilities and additions to tax as follows:
Additions to Tax Year Deficiencies Section 6653(b)1 19702 ...... $ 399.08 -0- 1972 ....... 5,848...
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