MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge:
Respondent determined the following deficiencies and penalties in respect of petitioner's Federal income taxes:
Sec. 6662(a) Taxable Year Deficiency Penalty 1989 .................... $12,284 $2,457 1990 .................... 12,251 2,450
Unless otherwise indicated, all...
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