MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge.
By notice of deficiency dated April 19, 2004 (the notice), respondent determined deficiencies in petitioner's Federal income tax and an accuracy-related penalty as follows:
Tax Year Ending Dec. 31 Deficiency Penalty Sec. 6662(a) 1996 $14,506 -- 1997 15,437 ...
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