Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $28,438 in petitioners' Federal income taxes for 1988, an addition to tax of $1,422 under section 6653(a)(1)(A), and an additional amount equal to 50 percent of the interest on $28,438 under section 6653(a)(1)(B). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year at issue, and all Rule references are to the...
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