MEMORANDUM FINDINGS OF FACT AND OPINION
HAINES, Judge:
Respondent determined the following deficiencies and penalties in petitioner's Federal income tax:
Year Deficiency Sec. 6662(a)1 Penalty Year Deficiency Sec. 6651(a)(1) 1999 $323,517.00 $64,703.40 2000 207,511.00 41,502.20
After concessions,
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