Memorandum Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' income tax for the calendar years 1981 and 1982 in the amounts of $11,781 and $5,356.45, respectively, and an addition to tax under section 6653(b) for the year 1981 of $15,837.50, and an addition to tax under section 6653(b)(1) for the year 1982 of $14,557.50, and an addition to tax under section 6653(b)(2) for the year 1982 of 50 percent of the interest due on $27,530.45...
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