MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Petitioners petitioned the Court to redetermine respondent's determinations with respect to their 1997, 1998, and 1999 Federal income taxes. Respondent determined the following deficiencies and section 6662(a) accuracy-related penalties for those years:
Year Deficiency Accuracy-Related Penalty 1997 $36,478 ...
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