MEMORANDUM FINDINGS OF FACT AND OPINION
KORNER, Judge:
Respondent determined deficiencies in and an addition to petitioners' Federal income taxes for the years and in the amounts as follows:
Addition to Tax Year Deficiency Sec. 6651(a)(1) 1987 ............. $79,252 -- 1988 ............. 7,004 $350
All statutory references...
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