MEMORANDUM FINDINGS OF FACT AND OPINION
MARVEL, Judge:
In separate notices of deficiency, respondent determined the following income tax deficiencies and penalties with respect to petitioners' Federal income tax returns for the taxable year 1995:
Walter O. Bowen & Susan M. Bowen, Docket No. 13714-99 Deficiency Sec. 6662(a) penalty $205,316 ...
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