Memorandum Findings of Fact and Opinion
PARKER, Judge:
Respondent determined a deficiency in petitioners' Federal income tax in the amount of $285,454 and an accuracy-related penalty under section 6662(a) in the amount of $57,091 for the taxable year 1989. Respondent also determined a deficiency in petitioners' Federal income tax in the amount of $375 for the taxable year 1990. These cases have been consolidated for purposes of trial, briefing, and opinion...
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