Memorandum Findings of Fact and Opinion
HAMBLEN, Chief Judge:
Respondent determined a deficiency in Ralph D. and Jacqueline L. Furlong's (petitioners) 1982 Federal income tax and additions to tax as follows:
Deficiency Additions to Tax $89,369 Sec. 6651(a)(1) ........... $10,398 Sec. 6653(a)(1) ........... 12,890 Sec. 6653(a)(2)............1 ...
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