Memorandum Findings of Fact and Opinion
WRIGHT, Judge:
By statutory notice of deficiency dated July 23, 1986, respondent determined deficiencies in petitioners' Federal income tax for taxable years 1981 and 1982 in the amounts of $5,302.20 and $12,421.40, respectively. Respondent also determined additions to tax in the following amounts:
Year Sec. 6653(a)(1)1 Sec. 6653...
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