Memorandum Opinion
RAUM, Judge:
The Commissioner determined the following deficiencies in income tax and additions to tax against petitioners for 1985 and 1986:
1985 1986 Deficiency $32,350 $19,133 Additions to Tax: Sec. 6651(a) 8,088 4,783 Sec. 6653(a)(1) 1,618 Sec. 6653(a)(1)(A) 957 Sec. 6653(a)(2)1
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