Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $7,711 and $6,952 in petitioners' Federal income taxes for 1985 and 1986, respectively. Respondent also determined additions to tax for fraud under section 6653(b) and for substantial understatement under section 6661. In the alternative, respondent determined that petitioners were liable for additions to tax under section 6653(a) for negligence for each year. Prior...
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