Memorandum Findings of Fact and Opinion
BEGHE, Judge.
Respondent determined a deficiency of $60,679 in petitioners' 1988 Federal income tax and additions to tax of $3,034 under section 6653(a)(1) and $15,170 under section 6661.
Unless otherwise identified, section references are to the Internal Revenue Code in effect for 1988, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After concessions by the parties, the...
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