MEMORANDUM OPINION
KORNER, Judge:
Respondent determined deficiencies in and accuracy-related penalties on petitioners' Federal income taxes for the years 1990 and 1991 as follows:
Penalty ---------- Year Deficiency Sec. 6662 1990 .................. $ 1,316.56 $ 263.31 1991 .................. 10,817.41 ...
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