MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined deficiencies in petitioners' Federal income tax and a penalty under section 6662 as follows:
Penalty Year Deficiency Sec. 6662 1994 .................... $ 9,614 $1,914 1995 .................... 11,855 2,356 1996 .................... 9,956 ...
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