Memorandum Findings of Fact and Opinion
FAY, Judge:
For petitioners' 1982 taxable year, respondent determined a Federal income tax deficiency in the amount of $6,615.20, a section 6661 addition to tax in the amount of $661.52, a section 6653(a)(1) addition to tax in the amount of $330.76, and a section 6653(a)(2) addition to tax in the amount of 50 percent of the interest due on the deficiency. The primary issue is whether petitioners' horse farming activity...
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