Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies in and additions to petitioners' Federal income taxes as follows:
Addition to Tax Year Deficiency Section 6653(b)1 1979 $41,139 $20,570 1980 27,752 13,876 1981 20,613 10,307
In the answer, respondent alternatively claimed...
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