MEMORANDUM FINDINGS OF FACT AND OPINION
THORNTON, Judge:
Respondent determined the following deficiencies and penalties with respect to petitioner's Federal income taxes:
Fraud Penalty Year Deficiency Sec. 6663(a) 1995 $4,025 $3,019 1996 21,271 15,954
After concessions, the principal issue remaining for decision is whether...
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