Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commission determined the following deficiency in, and additions to, the petitioners' Federal income tax for 1982:
Additions to Tax Sec. 6653(b)(1) Sec. 6653(b)(2) Deficiency I.R.C. 19541 I.R.C. 1954 $43,765.93 $21,882.96 $ 2,074.21
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