Memorandum Findings of Fact and Opinion
NIMS, Chief Judge:
Respondent determined the following deficiency in and additions to petitioners' Federal income tax for 1981:
Additions to Tax Deficiency Sec. 6651(a)(1) Sec. 6653(a)(1) Sec. 6653(a)(2) $23,118.00 $3,672.00 $1,867.00 50% of interest ...
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