GERBER, Judge:
Respondent, in a notice of deficiency dated April 9, 1985, determined deficiencies in petitioners' Federal income taxes and additions to tax as follows:
Year Deficiency Sec. 6659 addition1 1978 $4,165 $1,249 1979 3,882 1,165 1980 6,177 1,853 1981 8,548 2,564 1982 12,236 3,671
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