MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge:
In separate notices of deficiency, respondent determined deficiencies in petitioners' income taxes and penalties as follows:
Penalty Docket No. Year Deficiency Section 6662(a) 20218-98 1992 $34,515 $6,903 20219-98 1992 31,568 6,314
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