Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes and additions to tax under section 6661 for the calendar years 1986 and 1987 in the amounts as follows:
Addition to Tax Year Deficiency Sec. 6661 1986 ........................ $8,090 $2,023 1987 .....
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