MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
For 1996 and 1997, respondent determined deficiencies in petitioners' Federal income tax of $14,018 and $10,850 and penalties under section 6662(a) of $1,329.60 and $877.20, respectively. By amendment to the answer, respondent asserts increased penalties under section 6662(a) in the amounts of $863.40 and $605.80 for 1996 and 1997, respectively.
After concessions, the issues for decision are:...
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