MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge:
Respondent, by means of two separate notices of deficiency, determined deficiencies in petitioners' Federal income tax and an accuracy-related penalty as follows:
Penalty Year Deficiency Sec. 6662(a) 1991 .................. $11,344 -- 1992 .................. 15,419 $3,151...
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