Memorandum Findings of Fact and Opinion
DAWSON, Chief Judge:
Respondent determined a deficiency of $1,243 in petitioners' Federal income tax for the taxable year 1977 and an addition to tax under section 6653(a)
The issues for decision are (1) whether petitioners understated their taxable income in 1977; and, if so, (2) whether they are liable for the addition to tax under section 6653(a) for negligence or intentional...
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