Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
Respondent determined a deficiency in the Federal income tax liability of petitioners Beck (docket No. 24153-84) for their 1980 calendar year in the amount of $21,923.35. Respondent determined a deficiency in the amount of $32,283 and an addition to tax under section 6651(a)(1)
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