Memorandum Findings of Fact and Opinion
NIMS, Chief Judge:
Petitioners filed their 1982 Federal return on May 2, 1983. In a statutory notice of deficiency mailed May 2, 1986, respondent determined a deficiency in petitioners' 1982 Federal income tax of $11,556 and additions to tax in the amounts of $57.97 pursuant to section 6651(a)(1),
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