Memorandum Findings of Fact and Opinion
PANUTHOS, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) and Rules 180 et seq.
Respondent determined the following deficiencies in and additions to petitioners' Federal income tax for the taxable year 1986:
Bobby L. Butler, Docket No. 5474-90 Addition Deficiency
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