Memorandum Findings of Fact and Opinion
CLAPP, Judge.
Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1980 in the amount of $17,677 and additional interest under section 6621(c) in the amount of 120 percent of the interest due on the deficiency. All section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless...
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