MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge:
Respondent determined the following deficiencies in, addition to, and penalties on petitioners' Federal income tax:
Addition to Tax Penalty Sec. Year Deficiency Sec. 6651(a)(1) 6662(a) 2002 $31,482 --- $6,296.40 2003 16,996 $2,275.90 3,399.20
Unless otherwise...
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