Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined deficiencies in petitioners' Federal income tax and additions to tax as follows:
Theodore Arne and Flotilla Arne Additions to Tax Under Sections Year Deficiency 6651(a) 6653(a)(1) 6653(A)(2) 6653(a)(1)(A) 6653(a)(1)(B) 6661
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