GOLDMAN v. COMMISSIONER

MEMORANDUM OPINION

PAJAK, Special Trial Judge:

These cases were heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. All section references are to the Internal Revenue Code for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

Respondent determined additions to petitioners' Federal income taxes as follows:

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