SMITH v. COMMISSIONER

Memorandum Findings of Fact and Opinion

WRIGHT, Judge:

By notice of deficiency dated July 11, 1988, respondent determined the following additions to petitioners' Federal income tax for taxable year 1984:

             Additions to Tax
Sec. 66591   Sec. 6653(a)(1)    Sec. 6653(a)(2)

$3,731.40        $621.90        50% of the
                                interest due
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