Memorandum Findings of Fact and Opinion
WHALEN, Judge:
These consolidated cases involve two notices of deficiency in which respondent determined the following deficiencies in and additions to petitioners' Federal income tax:
Additional to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661...
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