HALE v. COMMISSIONER

Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

For the taxable year 1981 respondent determined a deficiency in petitioners' income tax and additions to tax as follows:

                                   Additions to Tax
  Deficiency         Section 6653(a)(1)       Section 6653(a)(2)1

  $9,790.00                $489.50            50% of the interest
                      ...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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