Memorandum Findings of Facts and Opinion
COLVIN, Judge:
The parties stipulated to deficiencies in income tax of $20,065 for 1982 and $45,272 for 1983. Petitioners seek to be relieved from their stipulation. They also argue reliance on accountants as a defense to respondent's determination of negligence, and contest the addition to tax for substantial understatement of income tax.
Respondent determined deficiencies and additions to tax as follows...
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