MEMORANDUM FINDINGS OF FACT AND OPINION
HAINES, Judge:
Respondent determined deficiencies in petitioner and intervenor's joint Federal income tax and accuracy-related penalties under section 6662(a) as follows:
Year Deficiency Sec. 6662(a) Penalty 2001 $22,178 $4,436 2002 8,669 1,734
The sole issue for decision is whether petitioner is entitled to...
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