- 2 -
and adopts the opinion of the Special Trial Judge which is set
forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
GOLDBERG, Special Trial Judge: Respondent determined the
following deficiencies and accuracy-related penalties with
respect to petitioners' Federal income taxes:
Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1991 $5,068 --
1992 9,388 $1,878
1993 7,279 1,456
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