MEMORANDUM FINDINGS OF FACT AND OPINION
FAY, Judge:
In these consolidated cases, respondent determined deficiencies in petitioners' Federal income taxes, an addition to tax, and accuracy-related penalties as follows:
Addition to Tax Penalty Year Deficiency Sec. 6661 Sec. 6662 1988 $8,645.96 $2,311 - 1989 1,966.00 - ...
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