MEMORANDUM FINDINGS OF FACT AND OPINION
PARKER, Judge:
Respondent determined a deficiency in petitioners' Federal income tax in the amount of $12,870 and an addition to tax under section 6651(a)(1) in the amount of $1,553 for the taxable year 1989 and a deficiency in the amount of $2,867 for the taxable year 1990.
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