MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Respondent determined deficiencies in the respective amounts of $60,907, $72,128, $77,072, and $8,243 in petitioners' 1989 through 1992 Federal income tax, an addition to tax under section 6651(a)(1) for 1989, and accuracy-related penalties under section 6662(a) for 1989 through 1992. Following concessions by both parties, we must decide: (1) Whether petitioners received constructive dividends in the amounts...
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