MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Chief Judge:
Respondent determined a deficiency in and additions to petitioners' 1986 Federal income tax as follows:
Additions to Tax, I.R.C. ------------------------------------------------------ Deficiency Sec. 6653(b)(1)(A) Sec. 6653(b)(1)(B) Sec. 6661(a) ...
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