Memorandum Findings of Fact and Opinion
HALPERN, Judge:
By notice of deficiency dated March 23, 1989, respondent determined deficiencies in petitioners' Federal income tax for the 1983, 1984, and 1985 taxable years, together with additions to tax for fraud under section 6653(b)(1) and (2), as follows:
Additions to Tax ---------------...
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