MEMORANDUM FINDINGS OF FACT AND OPINION
CLAPP, Judge:
Respondent determined the following deficiencies and accuracy-related penalties in petitioners' Federal income taxes:
Accuracy-related Year Deficiency Penalty Sec. 6662(a) 1990 ............ $686,872 $137,374 1991 ............ 805,093 161,019 1992 ............ 818,901 163...
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