MEMORANDUM OPINION
PARR, Judge:
Respondent determined deficiencies in, and penalties on, the Federal income tax for 1989, 1990, and 1991 of Carl E. Jones (petitioner) and Elaine Y. Jones (Mrs. Jones) as follows:
Accuracy-Related Year Deficiency Penalties Sec. 6662 1989 ............. $210,819 $42,164 1990 ............. 125,150 25,030 1991...
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