COX v. COMMISSIONER

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined deficiencies in and additions to petitioners' Federal income tax for the years and in the amounts as follows:

Year Ending   Deficiency      Section 6653(a)(1)&(a)(2)

 12-31-81       $101,228    $5,061   50% of the interest
                                     on $101,228
 12-31-82       $  3,250    $  163   50% of the interest
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