Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined a deficiency in petitioners' 1982 Federal income tax and additions to tax as follows:
Additions to Tax Deficiency Sec. 6653(a)(1)2 Sec. 6653(a)(2) $16,021.80 ............ $801.00 * * 50 percent of the...
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