Memorandum Findings of Fact and Opinion
WELLS, Judge:
Respondent determined the following deficiency in, addition to, and increased interest on the underpayment of petitioners' Federal income tax for taxable year 1977:
Addition to Tax Increased Interest Deficiency Sec. 6651(a)(1) Sec. 6621(c) $22,010.78 ........ $5,225.191
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