MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge.
In a notice of deficiency addressed to petitioners, respondent determined deficiencies and penalties as follows:
Penalty Year Deficiency Sec. 6662(a) 1993............... $114,257 $22,851 1994............... 171,550 34,310 1995............... 189,541 37,908
The...
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