Memorandum Findings of Fact and Opinion
SWIFT, Judge:
Respondent determined deficiencies in and additions to petitioners' Federal income taxes for the years 1973 through 1979 in a notice of deficiency dated April 15, 1981, and for the years 1980 through 1982 in a notice of deficiency dated March 11, 1985, as follows:
Addition to Tax, I.R.C. Sec.1 Year...
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