MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge:
Respondent determined penalties pursuant to section 6663 for taxable years 1992, 1993, and 1994 of $6,347, $22,350, and $28,454, respectively. In the alternative, respondent determined that petitioner is liable for accuracy-related penalties pursuant to section 6662(a).
Unless otherwise indicated, all section references are to sections of the Internal Revenue Code in effect at all relevant...
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