MEMORANDUM FINDINGS OF FACT AND OPINION
WHALEN, Judge:
Respondent determined the following deficiencies in, and penalties with respect to, the Federal income tax of petitioners Mark and Kay Pridgen, in the case at Docket No. 2048-97:
Penalty Sec. Year Deficiency 6662(a) 1990 ................. $129,169 $25,834 1991 ................. 232...
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