MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge.
Respondent determined deficiencies in petitioners' Federal income taxes and accuracy-related penalties as follows:
Penalty Year Deficiency Sec. 6662 1994 .......... $51,294 $10,259 1995 .......... 58,018 11,604 1996 .......... 45,101 9,020 1997 .......... 25,635 ...
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