MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge:
Respondent determined the following additions to petitioners' Federal income tax:
Additions to Tax --------------------------------------- Sec. Sec. Year 6653(a)(1)1 6653(a)(2) Sec. 6661(a) 1983 $1,393 * $6,965 * 50 percent of the...
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