MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notice dated March 9, 1998, respondent determined deficiencies of $23,938 and $92,548, and penalties, pursuant to section 6662(a), of $4,787.60 and $18,509.60, relating to petitioner's 1993 and 1994 Federal income taxes, respectively. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules...
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