Memorandum Opinion
KORNER, Judge:
Respondent determined deficiencies in tax and additions to tax against petitioners as follows:
Year Ending Deficiency in Additions to Tax1 December 31 Income Tax Section 6653(b)2 1976 ............. $ 10,303 $ 5,152 1977 ............. 63,644 31,822 1978...
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