Wright, Judge: Respondent determined a. deficiency of $41,089 in petitioners’ 1978 Federal income tax. Petitioners have conceded that they are liable for the entire deficiency. The issues for decision are (1) whether sections 6621(d)(1) 1 and 6621(d)(3)(A)(i) are unconstitutional as applied herein; (2) whether petitioners are liable for damages under section 6673; and (3) whethe…
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