Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' income tax for the calendar years 1979 and 1981, in the amounts of $16,920 and $509,982, respectively, and for 1979 additions to tax under section 6653(a) and section 6621(c) in the respective amounts of $846 and an amount to be determined for the year 1979.
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