MEMORANDUM FINDINGS OF FACT AND OPINION
WHALEN, Judge:
Respondent determined the following deficiency in, addition to, and penalty on petitioners' Federal income tax for 1993:
Penalty and Additions to Tax ------------------------------ Deficiency Sec. 6651(a)(1) Sec. 6662(a) $27,313 ................ $2,736 $5,463...
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