MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined deficiencies and penalties with respect to petitioners' Federal income tax as follows:
Penalty I.R.C. Sec. Year Deficiency 6663 1998 $43,020 $32,265.00 1999 42,510 30,672.75 2000 49,029 36,771.75
Unless otherwise indicated...
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