Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the calendar year 1986 in the amount of $233,876 and additions to tax as follows:
Sec. Sec. Sec. Sec. Sec. 6653(a)(1)(A) 6653(a)(1)(B) 6653(b)(1)(A) 6653(b)(1)(B) 6661 $4,716 ...
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