Memorandum Findings of Fact and Opinion
JACOBS, Judge:
This matter is before us on respondent's Motion for Entry of Decision which was filed when this case was called for trial.
Respondent determined a deficiency in petitioners' 1975 taxes in the amount of $11,854 and, with respect to Arthur R. King, III only, an addition to tax for fraud pursuant to section 6653(b)
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