MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge:
By notice of deficiency dated January 22, 2001 (the notice of deficiency), respondent determined deficiencies in, and penalties with respect to, petitioners' Federal income tax as follows:
Penalty Year Deficiency (Sec. 6662(a)) 1994 .............. $25,310 $5,062.00
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