MEMORANDUM FINDINGS OF FACT AND OPINION
PARKER, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the year 1989 in the amount of $38,758, an addition to tax under section 6651(a)(1) in the amount of $1,868, and an accuracy-related penalty under section 6662 in the amount of $7,752. By amendment to answer, respondent asserted an increased deficiency in income tax to the amount of $46,217, an increased addition to tax under section...
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