MEMORANDUM OPINION
TANNENWALD, Judge:
1 Respondent determined a deficiency in petitioners' 1987 Federal income tax in the amount of $138,290 plus an addition to tax of $34,573 under section 6661.
The issues for decision are whether petitioners: (1) Are entitled to a passthrough loss from a wholly owned S corporation, and (2) are liable for an addition to tax pursuant to section 6661 for a substantial understatement of...
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