MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notice dated December 10, 1997, respondent determined deficiencies of $21,977 and $7,266, and section 6662(a) penalties of $4,395 and $1,453, relating to petitioners' 1993 and 1994 Federal income taxes, respectively. All section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
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