MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge:
By notice of deficiency dated March 31, 1999 (the notice), respondent determined deficiencies in, and an addition and penalties with respect to, petitioners' 1992 through 1995 Federal income taxes, as follows:
Sec. 6651(a) Sec. 6662(a) Year Deficiency...
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