Memorandum Opinion
NIMS, Chief Judge:
Respondent determined the following deficiency in and additions to petitioners' Federal income taxes:
Additions to Tax-Sections Year Deficiency 6651(a)(1) 6653(a)(1) 6653(a)(2) 6661 1984 ............ $13,108 $1,072 $655 50% of interest $2,324 ...
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