Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $7,815, $3,415, and $1,209 in petitioners' Federal income tax for 1984, 1985, and 1986 and additions to tax under sections 6653(a)(1), 6653(a)(2), 6653(a)(1)(A), 6653(a)(1)(B), and 6661. Unless otherwise indicated, all section references are to the Internal Revenue Code as amended and in effect for the years in issue.
The issues for decision are (1) whether...
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