MEMORANDUM OPINION
COHEN, Judge:
Respondent determined deficiencies of $22,988 and $23,825 in petitioner's Federal income taxes for 1999 and 2000, respectively. Respondent also determined additions to tax of $1,987 and $5,527.25 under section 6651(a)(1) and $303.52 and $1,170.76 under section 6654 for those years, respectively. At the time of trial, respondent filed a motion for sanctions under section 6673. Unless otherwise indicated, all section...
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