Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for 1978 of $17,007 and an addition to tax under section 6653(a)1 (negligence) of $1,450. After various concessions by the parties,2 the issues for consideration are:
(1) Whether petitioners engaged in an activity concerning a chemical cell and wind turbine for profit...
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