MEMORANDUM OPINION
DEAN, Special Trial Judge:
Respondent determined deficiencies in petitioner's Federal income taxes of $6,727, $6,420, and $8,106 for taxable years 1993, 1994, and 1995, respectively. Respondent also determined accuracy-related penalties under section 6662(a) for taxable years 1993 and 1994.
At trial, respondent conceded that petitioner is not liable for penalties under section 6662(a). The sole issue...
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