Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $12,661 in petitioners' Federal income taxes for 1984 and additions to tax of $3,188 under section 6651(a)(1) and $2,177 under section 6661. Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and in effect for the year in issue. The deficiency resulted from disallowance of certain deductions claimed on Schedules A and C...
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