MEMORANDUM FINDINGS OF FACT AND OPINION
GALE, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes and an accuracy-related penalty as follows:
Accuracy-Related Year Deficiency Penalty Sec. 6662(b)(1) 1989 ............ $ 6,006 -- 1990 ............ 6,728 -- 1991 ............ 12,884 ...
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