Memorandum Findings of Fact and Opinion
PANUTHOS, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)
Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1985 in the amount of $6,955. Respondent also determined additions to tax as follows:
Sec. 6653(a)(1) Sec. 6653(a)(2) ...
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