Memorandum Findings of Fact and Opinion
NIMS, Judge:
By notice of deficiency dated June 19, 1981, respondent determined deficiencies in petitioners' income tax and additions to tax as follows:
Addition to Tax Year Deficiency Section 6653(b)1 1977 ........... $ 94,159.50 $47,079.75 1978 ........... 80,556.06...
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