Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $13,151, $12,020, and $7,983 in petitioners' Federal income tax for 1985, 1986, and 1987 and additions to tax under section 6661 for 1986 and 1987. Unless otherwise indicated, all section references are to the Internal Revenue Code as amended and in effect for the years in issue and all Rule references are to the Tax Court Rules of Practice and Procedure.
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