MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge.
Respondent determined deficiencies in petitioners' Federal income tax and penalties as follows:
Penalties Year Deficiency Sec. 6662 Sec. 6663 1995 $79,701 --- $58,241.25 1998 22,412 $2,187.80 48,376.50 1999 55,578 190...
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