MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge:
Respondent determined deficiencies in, and penalties on, petitioners' Federal income tax for taxable years 1991 and 1992 as follows:
Penalty Year Deficiency Sec. 6662(a) 1991 .................... $12,437 $2,487 1992 .................... 13,908 2,782
After concessions...
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