MEMORANDUM FINDINGS OF FACT AND OPINION
GOEKE, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes of $8,779, $9,835, and $15,498 and penalties pursuant to section 6662(a) of $1,755.80, $1,967, and $3,099.60 for the years 2000, 2001, and 2002, respectively.
1. Whether petitioner Dorothy M. Smith's direct marketing activities were conducted...
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