Memorandum Findings of Fact and Opinion
HAMBLEN, Judge:
Respondent determined additions to tax under sections 6653(a)(1) and (2) and 6661 in the respective amounts of $2,075.60, 50 percent of the interest due on $41,512, and $10,378 related to petitioners' understatement of income tax for the taxable year 1983 in the amount of $41,512. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the taxable year at issue...
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