MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined deficiencies in, and additions to, petitioners' Federal income taxes as follows:
Addition to Tax Year Deficiency Sec. 6651(a)(1) 1990 ................ $ 7,875 $1,922 1991 ................ 6,229 -- 1992 ................ 16,198 1,604
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