Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $18,027 in petitioners' Federal income taxes for 1988 and additions to tax of $4,053 under section 6651(a)(1) and $4,507 under section 6661. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The issues for decision are whether...
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