MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
By notice dated March 25, 1999, respondent determined deficiencies in and penalties on petitioners' Federal income taxes as follows:
Penalty Year Deficiency Sec. 6662(a) 1991 .................... $17,334 $3,467 1992 .................... 27,024 5,405 ...
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