MEMORANDUM OPINION
COLVIN, Judge:
This case is before the Court on respondent's motion for summary judgment and motion for a penalty under section 6673.
Respondent determined a deficiency in petitioners' Federal income tax of $498,933 for 1997, an addition to tax under section 6651(a) of $74,874.99, and an accuracy-related penalty under section 6662(a) of $99,786.60.
As discussed below, we will grant respondent's motion and will impose a...
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