Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $51,297 in petitioners' Federal income tax for 1984 and additions to tax of $2,565 under section 6653(a)(1); 50 percent of the interest due on the amount of the underpayment attributable to negligence under section 6653(a)(2); and $12,824 under section 6661(a). Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and in effect...
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