Memorandum Findings of Fact and Opinion
BEGHE, Judge:
On November 26, 1990, petitioners signed Form 870, consenting to the immediate assessment and collection of deficiencies in their 1987, 1988, and 1989 Federal income tax. Petitioners promptly paid the deficiencies shown on the Form 870. On August 27, 1991, respondent determined the following additional deficiency in and additions to petitioners' Federal income tax:
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