MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
In these consolidated cases, respondent determined deficiencies in petitioners' Federal income taxes and fraud penalties as follows:
Fraud Penalty Year Deficiency Sec. 6663 1993 ............... $192,142 $144,107 1994 ............... 185,261 138,946 1995 ............... 123,633...
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