Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent, in statutory notices of deficiency dated April 9, 1984, determined deficiencies in petitioners' income tax and additions to tax, as follows:
Augustine's Inc.—Docket No. 24323-84 Addition to Tax Taxable Year Ended Deficieny Section 6653(a)2 May 31, 1978...
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