Memorandum Findings of Fact and Opinion
WHALEN, Judge:
Respondent determined the following deficiency in, and additions to, petitioners' 1982 Federal income tax:
Additions to Tax ---------------------------------- Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) $11,336.28 ...... $566.81 50% of interest on ...
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