MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined deficiencies in and additions to tax and penalties with respect to petitioners' Federal income taxes as follows:
Bob J. & Ernestene Sams Docket No. 16023-99
Year Deficiency Sec. 6651(a)(1) Sec. 6662 1994 .................................... $16,793 $4,133 $3,358...
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