Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined deficiencies in petitioners' Federal income tax and additions to tax as follows:
Income Tax Additions to Tax Year Deficiency Section 6653(a)1 1979 ........... $3,251.38 $162.57 1980 ........... 5,741.01 287.05
After concessions,
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