Memorandum Opinion
COHEN, Judge:
Respondent determined deficiencies of $12,139, $16,006, and $19,079 in petitioner's Federal income taxes for 1984, 1985, and 1986, respectively. Respondent also determined that petitioner was liable for additions to tax under sections 6653(a)(1)(A) and (B) and 6661. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court...
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