MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Chief Judge:
Respondent determined deficiencies of $7,461 and $10,167 in petitioners' Federal income taxes for 1992 and 1993, respectively, and penalties of $1,492 and $2,033 under section 6662(a) for 1992 and 1993, respectively. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule...
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