MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge:
Respondent determined the following deficiencies in and penalties on petitioner's Federal income taxes:
Penalty Tax Year Ended Deficiency Sec. 6662(a) June 30, 1990 ....................... $ 2,473,392 $ 98,935 June 30, 1991 ....................... 12,772,856 ...
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