Memorandum Findings of Fact and Opinion
WHALEN, Judge:
Respondent determined a deficiency of $2,247.00 in petitioners' Federal income tax for calendar year 1985 and an addition to tax of $112.35, pursuant to section 6653(a)(1), and an additional amount equal to 50 percent of the interest payable on the amount of the underpayment, pursuant to section 6653(a)(2). All section references are to the Internal Revenue Code of 1954 as amended and in effect during...
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