Memorandum Opinion
BEGHE, Judge:
Respondent determined deficiencies in petitioner's Federal income tax and additions to tax for the taxable years 1985, 1986, and 1987, as follows:
1985 1986 1987 Deficiency .............................................. $48,041 $40,138 $166,806 Additions to Tax: Sec. 6651(a)(1) ............................
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