Memorandum Findings of Fact and Opinion
HAMBLEN, Chief Judge:
Respondent determined a deficiency in petitioners' 1982 Federal income tax in the amount of $13,374.28 and additions to tax as follows: Section 6653(a)(1) of $688.71, section 6653(a)(2) of 50 percent of the interest due on $13,374.28, and section 6661 of $3,343.57. Respondent also applied the increased interest rate set forth in section 6621(c).
All section references are to the Internal...
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