MEMORANDUM FINDINGS OF FACT AND OPINION
GERBER, Judge:
Respondent determined a deficiency in income tax and a fraud penalty for petitioners' 1993 tax year as follows:
Penalty Year Deficiency Sec. 6663(a)1 1993 ........... $103,559 $77,668.50
Respondent amended his answer to assert an increased deficiency and...
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