Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' income tax and additions to tax for the calendar years 1982 and 1983 in the following amounts:
Year Deficiency Sec. 6653(b)(1)1 Sec. 6653(b)(2) Sec. 6661(a) 1982 ......................... $1,552.00 $ 776.00 * ...
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