MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined deficiencies in, and penalties on, petitioners' Federal income tax liabilities as follows:
Penalty, I.R.C. Year Deficiency Sec. 6663(a) 1993 $ 41,582 $ 31,187 1994 57,974 43,481 1995 346,400 259,800
After concessions, the issues for...
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