MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge.
Petitioners petitioned the Court to redetermine respondent's determinations as to their 1993, 1994, and 1995 Federal income taxes. Respondent determined that petitioners were liable for the following deficiencies, accuracy-related penalties under section 6662(a), and fraud penalties under and 6663(a):
Years Deficiencies Sec. 6662...
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