MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
The issue for decision is whether petitioner is liable for deficiencies relating to 1996 and 1997 and a section 6662(a)1 accuracy-related penalty relating to 1996.
FINDINGS OF FACT
In the mid-1990s, petitioner formed Stephens City Chiropractic (SCC), a limited liability company; Win Enterprise (WIN), a limited company; Fair Hollow Trust (FHT), a domestic...
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