OPINION
NIMS, Judge:
Respondent determined the following deficiencies and penalties with respect to petitioners' Federal income taxes for the taxable years 1993, 1994, and 1995:
Taxable Income tax Penalty year deficiency sec. 6662(a) 1993 $74,925.00 $14,985 1994 127,304.00 25,461 1995 106,261.54 21,252 ...
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