Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined income tax deficiencies for the years 1974 and 1975 against Fred H. Kelly and Monsita E. Quave (formerly, Monsita E. Kelly), petitioner herein, in the respective amounts of $8,049.68 and $8,194.21.
Respondent also determined additions to tax under section 6653(b)
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