MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge:
This matter is before the Court on respondent's Motion for Summary Judgment, filed October 6, 1995, pursuant to Rule 121.
Respondent determined deficiencies in, an addition to, and accuracy-related penalties on, petitioners' Federal income tax for taxable years 1990 and 1991 as follows:
Addition...
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