Memorandum Findings of Fact and Opinion
WRIGHT, Judge:
Respondent determined a $22,781.34 deficiency in petitioners' Federal income tax for taxable year 1984 and additions to tax of $5,695.34 for failure to file under section 6651(a)(1), $1,139.07 for negligence under section 6653(a)(1), 50 percent of the interest due on $22,781.34 for negligence under section 6653(a)(2), and $5,695 for substantial understatement under section 6661.
Petitioners bear...
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