MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
The docketed cases are before the Court consolidated for trial, briefing, and opinion. Respondent determined deficiencies of $4,540, $1,849, and $1,204 in George Vajda's (petitioner's) 1994, 1995, and 1996 Federal income taxes, respectively. Respondent also determined that petitioner was liable for section 6662(a) accuracy-related penalties of $908, $370, and $241 for the respective years and a $120 addition...
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