Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By notice of deficiency dated December 6, 1982, respondent determined deficiencies in Federal income taxes for the years 1978, 1979, and 1980 against Philip D. Quint and Francine L. Quint in the respective amounts of $11,313, $12,448, and $3,719. Respondent also determined that Philip D. Quint is liable for the addition to tax under section 6653(b), I. R. C. 1954, for the years 1978, 1979, and 1980...
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