Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent, in a notice of deficiency, determined income tax deficiencies and additions to tax with respect to petitioners' 1983, 1984, and 1985 taxable years, as follows:
Additions to Tax Under Sections1 Year Deficiency 6651(a)(1) 6653(a)(1)* 6654 6661 1983 $ 4,553...
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