Memorandum Findings of Fact and Opinion
FAY, Judge:
For petitioners' 1987 tax year, respondent determined a deficiency in income tax of $87,736.00 and additions to tax pursuant to sections 6661, 6653(a)(1)(A) and (B) of $21,934.00, $4,386.80, and an amount to be determined, respectively. After concessions, the sole issue for decision concerns the valuation of goodwill.
Findings of Fact
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