Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $17,025.24 in petitioners' Federal income tax for 1984 and an addition to tax of $591.56 pursuant to section 6651(a)(1).
Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
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