Memorandum Findings of Fact and Opinion
WILLIAMS, Judge:
In these consolidated cases the Commissioner determined deficiencies and an addition to tax for petitioners' 1981, 1982, 1983, and 1984 taxable years as follows:
Addition to Tax Year Deficiency Sec. 6659 1981 .......... $20,060.00 -- 1982 ........... 12,907.00 -- 1983 .............
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