MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Judge:
Respondent determined the following deficiency in, and additions to, petitioners' 1988 Federal income tax:
Additions to Tax --------------------------------- Deficiency Sec. 6651(a)(1) Sec. 6653(a)(1) $155,255 $38,485 $7,856
Unless otherwise indicated, all section references are to the Internal...
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