MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge:
For 1985, respondent determined deficiencies in income tax and additions to tax against petitioners Larry B. Parker (Parker) and Martha A. Parker (Martha) resulting from their failure to report gain with respect to payments received in discharge of two $2 million notes. For 1985, respondent also determined deficiencies in income tax and additions to tax against Parker's two daughters, petitioners Tracy...
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