Memorandum Findings of Fact and Opinion
LARO, Judge:
W. Ryan Hovis and Jean H. Hovis petitioned the Court to redetermine respondent's determination of a $18,860 deficiency in their 1989 Federal income tax and a $3,307.75 addition thereto under section 6651(a)(1).
Section references are to the Internal Revenue Code in effect for the year in issue. Rule references are to the Tax Court Rules of Practice and Procedure. References to petitioner are to...
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