MEMORANDUM FINDINGS OF FACT AND OPINION
WHALEN, Judge:
Respondent determined the following deficiencies in and penalties with respect to the Federal income tax of petitioner Jerry L. Crabtree:
Fraud Year Deficiency Penalty Sec. 6663 1992 ............... $97,728 $73,296 1993 ............... 49,310 36,983 1994 ................
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