Memorandum Findings of Fact and Opinion
SWIFT, Judge:
In a timely notice of deficiency, respondent determined a deficiency in petitioners' 1984 Federal income tax and additions to tax as follows:
Addition to Tax, I.R.C., Secs. Year Deficiency 6653(a)(1) 6653(a)(2) 1984 ......... $1,438.00 $71.90 * ...
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