MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Docket Nos. 142-95 and 22884-95 are before the Court consolidated for purposes of trial, briefing, and opinion. Joseph Chu and Annie Chu petitioned the Court to redetermine respondent's determination of the following Federal income tax deficiencies and additions thereto:
Year Deficiency Penalties Sec. 6662(a) 1990 ............. $193,739 ...
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