Memorandum Findings of Fact and Opinion
NIMS, Chief Judge:
Respondent determined the following deficiency in and additions to petitioners' 1983 Federal income tax:
Additions to Tax-Sections Year Deficiency 6621(c) 6653(a)(1) 6653(a)(2) 6661 1983 $173,556.45 to be $8,677.82 50%...
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