OPINION
RUWE, Judge:
Respondent determined deficiencies in petitioners' 1987 Federal income taxes and additions to tax as follows:
Petitioner Deficiency Addition to tax sec. 6661 Rosemary S. Kovacs $220,572 $55,143 Lois E. Kovacs 34,992 8,748 Mary Ann Kovacs 33,103 8,276 Kathleen L. Kovacs 30,184 ...
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