MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge.
Respondent determined deficiencies in petitioners' Federal income tax and an addition to tax and a penalty as follows:
Faramarz Elghanian Addition to Tax and Penalty Year Deficiency Sec. 6661, I.R.C. Sec. 6662(a), I.R.C. 1987 $1,867...
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