MEMORANDUM FINDINGS OF FACT AND OPINION
MARVEL, Judge:
In separate notices of deficiency, respondent determined the following income tax deficiencies, penalties, and additions to tax with respect to petitioners' Federal income taxes:
Christopher K. Cox (Christopher) & Brenda M. Cox (Brenda), Docket No. 9989-99
Sec. 6662 Sec. 6651(a)(1)<...
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