MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Respondent determined deficiencies in petitioners' joint Federal income taxes and additions to tax for 1984 and 1985 and deficiencies in petitioner Michael W. Rehtorik's (petitioner's) individual Federal income taxes and additions to tax for 1986 and 1987, as follows:
Michael W. and Barbara B. Rehtorik Additions...
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