MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge:
Respondent determined deficiencies in 1989 income tax, and penalties as follows:
Fraud Penalty Petitioner Deficiency Sec. 6663 McDonald ............ $53,041 $39,781 Maynard ............. 71,380 53,535
After considering the parties' concessions and stipulations to be bound...
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