MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Chief Judge:
Respondent determined a deficiency of $14,173 in petitioners' Federal income taxes for 1995 and a penalty of $2,835 under section 6662(a). All section references are to the Internal Revenue Code in effect for the year in issue, unless otherwise indicated. The issue for decision is whether petitioners are liable for the penalty as determined by respondent.
FINDINGS OF FACT
Petitioners...
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