MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notice of deficiency dated December 5, 1994, respondent determined the following deficiencies and accuracy-related penalties:
Year Deficiency Penalty Sec. 6662(a) 1990 ............ $130,182 $ 26,036 1991 ............ 544,877 108,975 1992 ............ 413,649 82,730
Unless otherwise indicated...
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