MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined deficiencies in these consolidated cases of $2,636,238, $128,792, $79,135, $52,583, and $1,868,443 in petitioner's Federal income taxes for 1995, 1996, 1997, 1998, and 1999, respectively. Respondent also determined accuracy-related penalties under section 6662(a) of $527,247.60, $25,748.40, $15,827, $10,516, and $373,688.60 for the years in issue, respectively. Additionally, respondent...
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