Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' income tax for the calendar years 1979 and 1980 in the amounts of $22,467.68 and $12,182.84, respectively, and additions to tax under section 6621(c) (formerly section 6621(d)).
Some of the issues raised by the pleading have been disposed of by the parties, leaving for our decision: (1) Whether petitioners' purchase...
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