Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $13,689.33 in petitioners' Federal income tax for 1985 and additions to tax under section 6651(a)(1) of $688.51; section 6653(a)(1) of $775.77; section 6653(a)(2) of 50 percent of the interest payable under section 6601 with respect to the underpayment; and section 6661(a) of $3,422.33. Unless otherwise indicated, all section references are to the Internal Revenue...
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