Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent determined deficiencies in and additions to petitioners' Federal income tax for the years 1983, 1984, 1985, and 1986 in the following amounts:
Additions to Tax Under Sections Year Deficiency 6653(a)(1)2 6653(a)(1)(A) 6653(a)(2)
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