MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notices dated December 22, 1994, respondent determined deficiencies in petitioners' Federal income taxes as follows:
Kaiser Family Corporation (formerly kaiser Agency, Inc.), docket No. 3899-95 Year Deficiency 1990 ...................... $28,336 1991 ...................... 29,237 1992 ...................... 85,161 William H....
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