Memorandum Opinion
KÖRNER, Judge:
Respondent determined deficiencies of Federal income tax and additions to tax against petitioners for the years and in the amounts as follows:
Additions to Tax1 Year Deficiency Sec. 6651(a) Sec. 6653(a)(1)(A) Sec. 6653(a)(1)(B) 1986 .......... $8,842 ...
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