MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge:
Respondent determined deficiencies in petitioner's Federal income tax and penalties for the taxable years 1993, 1994, and 1995 as follows:
Penalty Year Deficiency Sec. 6662(a) 1993 $7,000 $1,400 1994 10,437 2,087 1995 10,725 ...
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