MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Dieter Stussy petitioned the Court to redetermine respondent's determinations concerning his 1992 through 1994 taxable years. Respondent determined the following income tax deficiencies and penalties for those years:
Year Deficiency Penalty Sec. 6662(a) 1992 ................. $8,316 $1,663 1993 ................. 8,014 ...
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