Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent determined a $3,758.25 deficiency, a $187.91 addition to tax under section 6653(a)(1) for negligence, and an addition under section 6653(a)(2) of 50 percent of the interest due on $3,758.25, against petitioners for their taxable year ending December 31, 1985.
Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and in effect for the taxable...
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