MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes and accuracy-related penalties as follows:
Accuracy-related Penalty Year Deficiency Sec. 6662(a) 1991 ........... $ 81,451 $ 16,290 1992 ........... 714,424 142,885 1993 ........... 477,936 ...
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