MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes for its fiscal years ended March 31, 1991 and 1992, in the respective amounts of $82,691 and $94,695 and accuracy-related penalties for these years under section 6662(b)(2) in the respective amounts of $16,538 and $18,939.
Following concessions by petitioner, the issues remaining for decision are: (1) Whether respondent properly...
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