Memorandum Opinion
WHALEN, Judge:
Respondent determined the following deficiency in, and addition to, petitioners' 1989 income tax:
Deficiency Addition to Tax Sec. 6662(a) $18,199 $3,640
After concessions, the sole issue for decision is whether petitioners are liable for the addition to tax for negligence under section 6662(a), as determined by respondent. All section references are to the Internal...
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