Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined a deficiency in petitioners' Federal income tax of $29,034.99 for the calendar year 1970, and an addition to tax under section 6651 (a)(1) of $16,846.65. After concessions made by the parties, the sole issue presented for decision is whether respondent properly imposed an addition to tax for the calendar year 1970 under section 6651(a)(1) of the Internal Revenue Code.
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