Memorandum Opinion
FAY, Judge:
Respondent determined the following deficiency in and additions to petitioners' Federal income tax:
Taxable Sec. Sec. Year Deficiency 6653(a)(1)1 6653(a)(2) 1983 $109,622 $5,481 * * 50% of the interest due on $109,622.
After concessions, the issues remaining for...
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