MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge.
Petitioner petitioned the Court to redetermine the following deficiencies in Federal income taxes and related section 6662(a) accuracy-related penalties:
Accuracy-Related Penalty Year Deficiency Sec. 6662(a) 1999 $294,389 $55,165.20 2000 405,286 81,057...
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