NEUMANN v. COMMISSIONER

MEMORANDUM OPINION

PAJAK, Special Trial Judge:

This case was heard pursuant to section 7443A(b)(3) of the Code and Rules 180, 181, and 182. All section references are to the Internal Revenue Code in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. Respondent determined additions to tax in petitioners' Federal income taxes as follows:

                             Addition to Tax
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