Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $9,775.78 in petitioners' Federal income taxes for 1984 and additions to tax of $154.47 under section 6651(a)(1), $683.44 under section 6653(a)(1), 50 percent of the interest due on $9,775.78 under section 6653(a)(2), and $2,443.94 under section 6661. Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and in effect for...
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