Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' 1982 Federal income tax and additions to tax as follows:
Additions to Tax --------------------------------------------- Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6659 1982 $19,260.82 $963.04
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