Memorandum Findings of Fact and Opinion
COLVIN, Judge:
Respondent determined a $91,784 deficiency in petitioners' Federal income tax for 1985 and additions to tax of $4,589 for negligence under section 6653(a)(1), 50 percent of the interest due on $91,784 for negligence under section 6653(a)(2), and $22,946 for substantial understatement of income tax under section 6661.
After concessions, the issues remaining to be decided are:
1. Whether...
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