MEMORANDUM OPINION
WELLS, Judge:
Respondent determined the following deficiencies in income tax, additions to tax, and penalties for petitioner's taxable years 1999, 2000, 2001, and 2002:
Year Deficiency 6651(a)(1) 6651(a)(2) 6651(f) 6654(a) 1999 $75,888 - $18,972 $55,018.80 $3,672.67 2000 69,302 -2
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