SHIELDS, Judge:
In a deficiency notice dated February 5, 1987, respondent determined that there was a deficiency in petitioners' income tax for 1984 in the amount of $12,491 and that they were liable for additions to tax under sections 6653(a) and 6661, I.R.C. 1954, in the respective amounts of $624.55 and $3,122.75. When the case was called from the calendar for trial on April 11, 1988, the parties filed a stipulation of settled issues in which respondent...
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