MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge.
Respondent determined deficiencies in petitioners' joint Federal income taxes for 1989, 1990, and 1991, and accuracy-related penalties for 1989 and 1990, as follows:
Accuracy-Related Penalty Year Deficiency Sec. 6662(a) 1989 .......... $28,242 $5,648 1990 .......... 24,401 4...
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