Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined deficiencies of $39,079 and $27,675 in petitioner's Federal income taxes for 1985 and 1986, respectively, and additions to tax under sections 6653(a) and 6661 for each year. Unless otherwise indicated, all section references are to the Internal Revenue Code as 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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