MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined that petitioners had deficiencies in Federal income tax of $8,276 for 1989, $21,265 for 1990, and $1,901 for 1991.
Petitioners bought all of the stock of Seattle Pump Company, Inc. (Seattle Pump). They gave the seller a note secured by letters of credit. The letters of credit were secured in part by a deed of trust on petitioners' residence. Seattle Pump employed petitioner...
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