PELHAM v. COMMISSIONER

Memorandum Findings of Fact and Opinion

PANUTHOS, Chief Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181 and 183.1

Respondent determined deficiencies in and additions to petitioners' Federal income tax for the taxable years 1985 and 1986 as follows:

                                                              Additions To Tax
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