Memorandum Opinion
HALPERN, Judge:
Respondent determined a deficiency of $19,809 in petitioners' Federal income tax for 1985. Respondent also determined additions to tax of $2,929.14 under section 6651(a)(1); $990.45 under section 6653(a)(1); and 50 percent of the interest due on the underpayment, under section 6653(a)(2), for 1985.
Unless otherwise noted, all section references are to the Internal Revenue Code in effect for the year in issue, and...
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