Memorandum Findings of Fact and Opinion
HAMBLEN, Judge.
Respondent determined deficiencies and additions to tax in Bailey Yelding, Jr.'s (hereinafter petitioner), and his wife, Elizabeth Yelding's (together hereinafter referred to as petitioners), Federal income tax for the taxable years 1985, 1986, and 1987 as follows:
Additions to tax under sections1 : Year Deficiency...
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