Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined a deficiency in petitioners' Federal income tax of $25,818.00 for the taxable year 1983. He also determined an addition to tax under section 6653(a)(1) in the amount of $1,290.90 and that petitioner is liable for an additional 50 percent of the interest due on the part of the deficiency attributable to negligence under section 6653(a)(2). In light of respondent's concession...
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