MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined a deficiency of $8,418 in petitioners' Federal income tax and an addition to tax under section 6661(a) in the amount of $1,684 for the taxable year 1989. By amendment to answer, respondent subsequently increased the deficiency in petitioners' Federal income tax to $11,705 and increased the addition to tax to $2,341, correcting the applicable section reference to section 6662(a)....
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