Memorandum Findings of Fact and Opinion
WRIGHT, Judge:
By notice of deficiency dated December 13, 1985, respondent determined the following deficiencies in petitioners' Federal income tax and additions to tax:
Addition to Tax Year Deficiency Sec. 6653(a)1 1979 ........... $18,751.00 $ 937.59 1980 ........... 63,020.18 ...
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