Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent determined a $288,250.93 deficiency and a $13,259.10 addition to tax under section 6651(a)(1)
On brief, petitioners concede that they are liable for the addition to tax under section 6651(a)(1). Furthermore, the parties agree that $165,000 is a partnership distribution within the meaning...
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