MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes and penalties as follows:
Penalty ------------ Year Deficiency Sec. 6662(a) 1991 ........... $14,997 $2,999 1992 ........... 18,847 3,769 1993 ........... 17,898 ...
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