MEMORANDUM FINDINGS OF FACT AND OPINION
BEGHE, Judge:
Respondent determined the following deficiencies and accuracy-related penalties in petitioner's Federal income tax:
Accuracy-Related Penalty Year Deficiency Sec. 6662 1990 ......... $ 7,680 $1,536 1991 ......... 7,139 1,428 1992 ......... 12,209 2,442
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