Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined a deficiency against petitioners consisting solely of an addition to tax in the amount of $1,163.28 for failure to file a timely return for the taxable year 1961 under section 6651(a) of the Internal Revenue Code of 1954.
Petitioners are husband and wife and had their legal residence in New York City, New York, at the time the petition herein...
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