Memorandum Opinion
SWIFT, Judge:
This case is before the Court on respondent's motion for summary judgment. Respondent determined a deficiency in petitioners' 1977 joint Federal income tax in the amount of $22,011, an addition to tax under section 6651(a)(1) in the amount of $5,225, and increased interest under section 6621(c).
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and...
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