Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined a deficiency of $275,647 in petitioners' 1984 Federal income tax and additions to tax under section 6651 in the amount of $68,952 and under section 6661 in the amount of $68,912.
All section references are to the Internal Revenue Code in effect for the year at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated....
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