Memorandum Opinion
COHEN, Judge:
In docket No. 16751-83, respondent determined deficiencies of $22,197.50 and $23,117.50 in petitioners' Federal income taxes for 1979 and 1980. In docket No. 30027-85, respondent determined deficiencies in and additions to petitioners' Federal income taxes as follows:
Additions to Tax, I.R.C. Year Deficiency Sec. 6653...
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