MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined deficiencies and penalties with respect to petitioners' Federal income tax as follows:
Year Deficiency Sec. 6662 Penalty 1995 $119,377 $23,875 1996 68,663 13,733 1997 4,849 970 1998 14,3821 2,876
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