MEMORANDUM FINDINGS OF FACT AND OPINION
GALE, Judge.
Respondent determined the following deficiencies in, and additions to, petitioners' Federal income tax:
Daniel G. Callahan Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6654(a) 1997 $2,936 $734.00 $157.07 1998 3,064 766...
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