Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency in and additions to petitioners' Federal income tax as follows:
Additions to Tax ---------------------- Sec. Year Deficiency 6653(a)(1) Sec. 6661 1983 $33,093 $1,654.65 $8,273.25
Respondent also determined that petitioners were liable for an addition to tax...
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