MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Chief Judge:
Respondent determined deficiencies in petitioner's Federal income taxes and penalties as follows:
Penalty Year Deficiency Sec. 6662(a) 1991 .................. $4,718 $ 944 1992 .................. 5,026 1,005 1993 .................. 6,253 1,251...
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