Memorandum Findings of Fact and Opinion
PARKER, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the year 1988 in the amount of $360,336 and additions to tax under section 6653(a)(1) in the amount of $18,017 and under section 6661(a) in the amount of $90,084.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year before the Court, and all Rule references are...
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