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MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: By notices of deficiency dated February 24,
1997, respondent determined deficiencies in, additions to, and
penalties with respect to petitioners’ Federal income taxes for
their taxable (calendar) years 1987 through 1991 (the audit
years), as follows:
Additions to Tax and Penalties
Sec. Sec. Sec.
Year Deficiency 6654 6653(b)(1) 6663
1987 $46,346 $2,587 1$36,140 --
1988 59,016 4,593 53,558 --
1989 12,444 1,535 -- $9,333
1990 67,887 5,393 -- 50,915
1991 9,371 1,104 -- 7,028
1 Plus 50% of the interest due on underpayment of $48,187
due to fraud. Sec. 6653(b)(1)(B).
Because of the complicated procedural history of this case,
we set forth in some detail the disposition of various issues
that the parties, themselves, have agreed to or disposed of. By
motion for leave to file amended answer, respondent informed the
Court that he had determined not to pursue the penalties
determined under sections 6653(b)(1) and 6663, for fraud. We
interpret that as a concession, and we accept it. By the amended
answer to amended petition, respondent admits that there are no
deficiencies in tax for 1989, 1990, and 1991, and, for 1987 and
1988, he claims additions to tax for delinquency under section
6651 and for negligence under section 6653(a). By a stipulation
of settled issues, petitioners concede the claimed addition to
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