Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $2,290 and $16,087 in petitioners' Federal income taxes for 1984 and 1985, respectively. Respondent also determined additions to tax under sections 6651(a)(1) and 6653(a)(1) and (2) for 1984 and under sections 6653(a)(1) and (2) and 6661 for 1985. All section references are to the Internal Revenue Code as in effect for the years in issue, and all Rules references...
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