MEMORANDUM FINDINGS OF FACT AND OPINION
WHALEN, Judge:
Respondent determined the following deficiencies in, and penalties with respect to, Mr. Michael Vetrano's Federal income tax for 1991 and 1992:
Year Deficiency Fraud Penalty 1991 ............... $10,488 $7,866 1992 ............... 10,600 7,950
Respondent also determined the following deficiency and penalty with respect...
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