MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
In an "affected items" notice of deficiency sent June 19, 2006, respondent determined that petitioners are liable for additions to tax for 1982 as follows:
Additions to Tax Year Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661 1982 $351 * $1,755 * 50 percent of the interest on $7,020.
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