MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Judge:
Respondent determined deficiencies in petitioners Federal income tax and accuracy-related penalties as follows:
Penalties Year Deficiency Sec. 6662 1991 $3,009,338 $601,868 1992 1,704,166 340,833 1993 605,629 121,125
Unless otherwise indicated, all section...
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