Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
In a deficiency notice dated July 3, 1990, respondent determined deficiencies in and additions to petitioners' Federal income taxes as follows:
Additions to Tax Year Deficiency Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6661(a) 1982 ..................... $19...
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