Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1979 in the amount of $196,182 and an addition to tax under section 6653(a) in the amount of $9,809. All section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. These cases were...
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