MEMORANDUM OPINION
LARO, Judge:
Richard T. and Miriam Stanley petitioned the Court to redetermine 1992 through 1994 income tax deficiencies of $97,474, $152,220, and $5,569, respectively, and accuracy-related penalties for negligence under section 6662(a) for each of these years. Unless otherwise stated, section references are to the Internal Revenue Code in effect for the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure...
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