Memorandum Findings Of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $10,779 in petitioners' Federal income taxes for 1987 and additions to tax under sections 6651(a)(1) and 6653(a)(1)(A) and (B) in the amounts of $2,026, $658, and 50 percent of the interest due on the deficiency, respectively. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references...
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