MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge:
Respondent determined the following deficiencies and accuracy-related penalties with respect to the Federal income tax of petitioner, John R. Boone, Jr., for the taxable years 1989 and 1990:
Penalties Year Deficiency Sec. 6662(a) 1989 ................... $11,775 $2,415 1990 ............
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