MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined deficiencies in petitioner's income tax of $53,524 for 2000 and $81,458 for 2001 and that petitioner is liable for additions to tax for failure to file under section 6651(a)(1) of $13,381 for 2000 and $20,364.50 for 2001 and for failure to pay estimated tax under section 6654 of $2,858.96 for 2000 and $3,255.36 for 2001.
The issues for decision are:
1. Whether respondent...
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