Memorandum Opinion
HALPERN, Judge:
By notice of deficiency dated August 21, 1987, respondent determined a deficiency in petitioners' Federal income tax in the amount of $29,015, for the taxable year 1983, together with an addition to tax under section 6661. In an amended answer filed on September 26, 1988, respondent increased the deficiency to $61,011.50 and conceded that section 6661 was inapplicable. The deficiency at issue derives from respondent's disallowance...
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