MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notice dated April 15, 1997, respondent determined deficiencies of $38,110, $38,098, and $18,119, and section 6662(a) penalties of $7,622, $7,620, and $3,624, relating to Kenneth Schoeneman's 1993, 1994, and 1995 Federal income taxes, respectively. All section references are to the Internal Revenue Code in effect for the years in issue. The executors of Kenneth's estate resided, and had a business...
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