GOODWIN, Circuit Judge:
Zachary and Salley Sacks appeal an order imposing penalties for the negligent under-payment of taxes. 26 U.S.C. §§ 6653(a) and 6661(a). We affirm the judgment of the Tax Court.
I.
The facts of this case are set out in detail in the Tax Court's opinion. We summarize the most pertinent ones here.
The Sacks claimed investment losses and deductions for 1981 and 1982 from their participation in Far West Drilling...
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