Memorandum Findings of Fact and Opinion
BEGHE, Judge:
Respondent determined a deficiency of $429,717 in the Meyerses' 1987 Federal income tax. Respondent also determined that the Meyerses are liable for additions to tax for substantial understatement of tax and negligence in the respective amounts of $107,429 and $21,486, plus 50 percent of the interest due on the deficiency.
Sylvia R. Meyers died in 1992, after the petition in this case was filed...
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