Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $40,045 in petitioners' Federal income tax for 1987 and an addition to tax of $12,014 under section 6659A. All section references are to the Internal Revenue Code in effect for 1987, and all Rule references are to the Tax Court Rules of Practice and Procedure.
The deficiency and addition to tax resulted from respondent's disallowance of petitioners' pension...
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