MEMORANDUM FINDINGS OF FACT AND OPINION
KROUPA, Judge.
Respondent determined deficiencies and penalties with respect to petitioner's income taxes for 1999, 2000, and 2001 (the years at issue). For 1999, respondent determined a $12,769.70 deficiency and determined petitioner was liable for a $2,273.94 accuracy-related penalty under section 6662.
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