Memorandum Findings of Fact and Opinion
COLVIN, Judge:
Respondent determined deficiencies in petitioners' Federal income tax of $15,507.61 for 1985, and additions to tax of $768.38 for negligence under section 6653(a)(1), 50 percent of the interest due on the negligence portion of any underpayment under section 6653(a)(2), and $3,841.90 for substantial understatement of income tax under section 6661(a). Respondent has conceded the additions to tax.
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