MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge:
Respondent determined income tax deficiencies for petitioners' 1987 and 1988 taxable years in the amounts of $24,716 and $91,878, respectively. Respondent also determined additions to tax for negligence in the amounts of $1,236 for 1987 and $4,594 for 1988. After considering agreements and concessions by the parties, the remaining issues are: (1) Whether...
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