Memorandum Opinion
PARKER, Judge:
Respondent has determined a deficiency in petitioners' Federal income tax and additions to tax as follows:
Additions to Tax Sec. Sec. Taxable Year Deficiency 6653(a)(1) 6653(a)(2) 1985 ........... $20,360 $1,018 * * 50% of the interest due on the deficiency...
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