NIMS, Judge:
For the year 1989, respondent determined the following deficiency in petitioners' Federal income tax and penalties:
Addition to tax Penalty Deficiency sec. 6651(a)(1) sec.6662(a) $79,092 $19,773 $15,818
Unless otherwise stated, all section references are to the Internal Revenue Code in effect for the year 1989, and all Rule...
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