OPINION
TANNENWALD, Judge:
Respondent determined deficiencies in petitioners' Federal income tax as follows:
Additions to tax --------------------------------- Year Deficiency Sec. 6653(a)1 Sec. 6654 1974 $585,488.12 $29,274.40 $18,693.93 1975 86,591.06 4,329.55 3,730.16...
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