MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge.
Respondent determined the following deficiencies and penalties with respect to petitioner's Federal income taxes for the taxable years 1993 and 1994:
Income Tax Penalty Taxable Year Deficiency Sec. 6663 1993 ................... $60,212 $45,159 1994 ................... 38,407 28,805...
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