POPLAR v. COMMISSIONER

MEMORANDUM FINDINGS OF FACT AND OPINION

ARMEN, Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b) and Rules 180 et seq.1

Respondent determined deficiencies in, and additions to, petitioners' Federal income taxes for the taxable years 1980, 1981, and 1983 as follows:

                                                       Additions to Tax
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