Memorandum Findings of Fact and Opinion
PARKER, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1989 in the amount of $20,419. Respondent also determined an addition to tax for failure to timely file under section 6651(a) in the amount of $902 and an accuracy-related penalty under section 6662(a) in the amount of $4,084.
Unless otherwise indicated, all section references are to the Internal Revenue...
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