Memorandum Findings of Fact and Opinion
KORNER, Judge:
In his notice of deficiency respondent determined deficiencies in petitioners' Federal income tax and additions to tax as follows:
Addition to Tax Year Deficiency Sec.6653(a)1 1978 $ 6,976.18 $ 348.81 1979 39,707.17 1,985.34 1980 10,214.68 510.73
After concessions,
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