Memorandum Opinion
GALLOWAY, Special Trial Judge:
Petitioners Harold A. Chamberlain and Janice Chamberlain, husband and wife, filed a joint income tax return in 1977, using the cash basis of accounting. Respondent determined a deficiency of $32,704.63 in petitioners' 1977 Federal income tax and an addition to tax of $1,655.23 under section 6653(a).
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