MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge.
Respondent determined deficiencies and accuracy-related penalties with respect to petitioner's Federal income tax as follows:
Accuracy-Related Penalty Year Deficiency Sec. 6662(a) 1992 ............... $57,466 $11,493 1993 ............... 39,669 7,934 1994 ............... ...
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