Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $7,164 and $7,516 in petitioner's Federal income taxes for 1986 and 1987, respectively, and additions to tax under section 6661(a)(1) of $1,791 and $1,879, respectively, for those years. The issues for decision are whether petitioner is entitled to deductions relating to his sailboat charter activity and whether he is liable for the additions to tax determined by...
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