MEMORANDUM FINDINGS OF FACT AND OPINION
WHALEN, Judge:
Respondent determined the following deficiencies in, and penalties on, petitioners' income taxes:
Penalty Year Deficiency Sec. 6662 1990 .................... $ 470 $ 270 1991 .................... 4,345 1,114 1992 .................... 5,320 1,428...
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