MEMORANDUM OPINION
ARMEN, Special Trial Judge:
These consolidated cases were heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
Respondent determined deficiencies in petitioners' Federal income taxes for the taxable years 1988, 1989, and 1990, as well as an addition to tax and a penalty for negligence, as follows:
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