Memorandum Findings of Fact and Opinion
COLVIN, Judge:
By notice of deficiency sent to petitioners on December 29, 1986, respondent determined deficiencies, additions to tax, and increased interest as follows:
Sec. 6653(a)1 or Year Deficiency Sec. 6653(a)(1) Sec. 6621(c) 1980 .......
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