Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
In a deficiency notice dated April 14, 1989, respondent determined deficiencies in and additions to petitioners' Federal income taxes as follows:
Additions to tax under sections Year Deficiency 6653(a)(1)1 6653(a)(2) 6661 12/31/82 $15,967.25 $966.31 50% of the...
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