Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined a deficiency in and additions to petitioner's 1986 Federal income tax as follows:
Additions to Tax Under Secs.1 Deficiency 6653(b)(1)(A) 6653(B)(1)(B) 6661(a) $67,869 $50,902 * $16,967 * 50 percent of the interest due on the portion of the underpayment...
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