MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Petitioners petitioned the Court to redetermine respondent's determinations as to their 1994 and 1995 Federal income taxes. For 1994, respondent determined in a notice of deficiency issued to petitioners that they were liable for a $66,798 deficiency, a $16,149 late-filing addition to tax under section 6651, and a $13,360 accuracy-related penalty for negligence under section 6662.
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