MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Donald J. Kenney and Linda L. Kenney petitioned the Court to redetermine respondent's determinations with respect to their 1989 and 1990 taxable years. Respondent determined the following Federal income tax deficiencies and accuracy-related penalties for those years:
Penalty Sec. 6662(a) Year...
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