Memorandum Opinion
NIMS, Chief Judge:
Respondent determined deficiencies in, additions and increased interest to petitioners' Federal income taxes as follows:
Year Deficiency Section 6659 Section 6661 Section 6621(c) 1982 ....................... $8,111 $1,834 $1,956 * 1983 ....................... 7,842 -- 2,441 ...
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