Memorandum Findings of Fact and Opinion
COLVIN, Judge:
Respondent determined a $95,825 deficiency in petitioners' Federal income tax for 1988 and additions to tax for negligence under section 6653(a) in the amount of $4,791 and for substantial understatement of tax under section 6661 in the amount of $22,907.
After concessions, the issues for decision are:
(1) Whether a principal purpose of petitioners' transfer of two properties to the Metropolitan...
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