MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Petitioners petitioned the Court to redetermine a $215,493 deficiency in their 1995 Federal income tax and a $43,099 accuracy-related penalty under section 6662(a). Following respondent's concession as to 17 of the 23 bank deposits determined by him in the notice of deficiency to be income, and our granting of petitioners' motion to dismiss much of this case for lack of jurisdiction,
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