Memorandum Finding of Fact and Opinion
WHALEN, Judge:
Respondent determined the following deficiency in and additions to petitioner's Federal income tax for taxable year 1983:
Sec. Sec. Deficiency 6653(a)(1)1 6653(a)(2) $2,835.00 $141.75 * * 50 percent of the interest due on the underpayment.
The issues for decision are...
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