MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge:
Respondent determined deficiencies in, and penalties on, the Federal income tax for 1992, 1993, and 1994 of Terry F. Zdun (petitioner) and Carol J. Zdun (Mrs. Zdun) as follows:
Accurancy-Related Year Deficiency Penalty Sec. 6662(a) 1992 ............... $ 6,668 $1,334 1993 ............... ...
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