MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge:
Respondent determined deficiencies in petitioners' Federal income and gift taxes and additions to tax as follows:
Lynnda Speer, Donor Gift tax—docket No. 6626-94 Year ............................... Deficiency 1990 ............................... $625,702 Roy M. and Lynnda L. Speer
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