Memorandum Opinion
NAMEROFF, Special Trial Judge:
This matter is before the Court on respondent's Motion for Leave to File an Amendment to Answer. A hearing on the motion was held in Los Angeles, California on October 25, 1989. The parties have submitted memoranda in support of their respective positions.
Respondent determined deficiencies in petitioners' Federal income tax and additions to tax for the taxable years 1978, 1980 and 1981 as follows...
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