Memorandum Findings of Fact and Opinion
WHALEN, Judge:
Respondent determined the following deficiencies in, and additions to, petitioners' Federal income tax:
Addition to Tax Year Deficiency Sec. 6653(b) 1978 ....................... $18,713 $ 9,357 1979 ....................... 34,160 17,080 1980 ......................
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