MEMORANDUM FINDINGS OF FACT AND OPINION
CHIECHI, Judge:
Respondent determined the following deficiencies in, and accuracy-related penalties on, petitioners' Federal income tax:
Accuracy-Related Penalty Year Deficiency Section 6662(a)1 1989 ........ $235,120 $47,024 1990 ........ 95,898 19,180
The...
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