Memorandum Opinion
RUWE, Judge:
Respondent determined a deficiency in petitioners' 1988 Federal income tax and additions to tax as follows:
Additions to Tax --------------------------- Deficiency Sec. 6651(a)(1) Sec. 6661 $29,228 $1,335 $7,307
After concessions, the issues for decision are: (1) Whether, under section 1034,
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