MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge.
These consolidated cases concern the 1989 and 1990 Federal income taxes of Charles L. Garavaglia (Mr. Garavaglia) and Mary Ann T. Garavaglia (Ms. Garavaglia) (collectively, the Garavaglias or petitioners). Respondent determined deficiencies in Mr. Garavaglia's 1989 and 1990 Federal income taxes of $97,070 and $114,435 and fraud penalties under section 6663(a) of $72,803 and $85,826, respectively.
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