MEMORANDUM FINDINGS OF FACT AND OPINION
SCOTT, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes and additions to tax for the taxable years 1985 through 1988 as follows:
Additions to Tax Year Deficiency Sec. 6651(a)(1) 1985 ............... $6,890 $813 1986 ............... 7,080 685 1987 .............
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