Memorandum Findings of Fact and Opinion2
GERBER, Judge:
Respondent, by a notice of deficiency dated March 30, 1984, determined income tax deficiencies and additions to tax in petitioners' 1980, 1981 and 1982 taxable years, as follows:
Income Tax Additions to the Tax Year Deficiencies Sec. 6653(a)(1)
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