MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge.
Respondent determined deficiencies of $35,003 and $1,648 in petitioners' 2012 and 2013 Federal income tax, respectively, an addition to tax of $8,747 for 2012 for failing timely to file a return, and accuracy-related penalties of $7,001 and $330 for both years, respectively.
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