MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Walter E. Hess and Helen L. Hess petitioned the Court to redetermine respondent's determination of the following deficiencies in Federal income tax and accuracy-related penalties under section 6662(a):
Accuracy-Related Penalty Year Deficiency Sec. 6662(a) 1992 ............ $ 17,970 $ 3,594...
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