STEFANSSON v. COMMISSIONER

Memorandum Findings of Fact and Opinion

RUWE, Judge:

Respondent determined a deficiency in petitioners' 1987 Federal income tax and additions to tax as follows:

                              Additions to Tax
             -------------------------------------------------
Deficiency   Sec. 6653(b)(1)(A)   Sec. 6653(b)(1)(B)   Sec. 6661

 $65,259        $48,944.25        50 percent of the    $16,314.75
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