MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Respondent determined deficiencies in petitioners' joint Federal income taxes and accuracy-related penalties for 1989 through 1992 as follows:
Stuart and Betsy Bobry Docket No. 5007-94 Accuracy-Related Penalty Year Deficiency Sec. 6662(c) 1989 .... $991,916 $198,383 1990 .... 563,956 ...
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