Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined an addition to tax of $12,343 under section 6661 and increased interest under section 6621(c) for petitioners' 1985 Federal income tax. The addition to tax and the increased interest are attributable to an adjustment made to the income of Penndade Associates Limited Partnership (Penndade), which resulted in an automatic adjustment to petitioners' income pursuant to the provisions...
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