Memorandum Findings of Fact and Opinion
NIMS, Judge:
Respondent determined a deficiency in petitioners' income tax for the year 1975 in the amount of $1,959.92. Due to alleged negligence or intentional disregard of rules and regulations, respondent imposed an addition to the tax of $97.98, under section 6653(a).
Due to concessions made by respondent, the issues remaining for decision are:
(1) Whether petitioners...
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