Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined a deficiency in and additions to petitioners' Federal income tax for the tax year ended December 31, 1981, as follows:
Additions to Tax Deficiency Sec. 6653(a)(1)1 Sec. 6653(a)(2) $240,919 $12,045 * * 50 percent of the interest due on the determined deficiency...
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