ADAIR v. COMMISSIONER

MEMORANDUM FINDINGS OF FACT AND OPINION

SWIFT, Judge:

In these consolidated cases, respondent determined deficiencies in petitioners' Federal income taxes and fraud penalties as follows:

                                    Fraud Penalty
Year                   Deficiency     Sec. 6663

1993 ...............    $192,142       $144,107
1994 ...............     185,261        138,946
1995 ...............     123,633...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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