Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined deficiencies in and additions to petitioners' income taxes as follows:
Additions to Tax1 Section Section Year Deficiency 6653(a)(1) 6653(a)(2) 1982 $10,956.49 $ -- $ -- 1983 $10,764.00 $538.20 50 percent of the ...
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