MEMORANDUM FINDINGS OF FACT AND OPINION
HAINES, Judge.
Respondent determined deficiencies in petitioner's Federal income taxes for 2000, 2001, 2002, and 2003 (years at issue) of $24,351, $24,222, $25,608, and $26,426, as well as additions to tax under section 6651(a)(1) of $6,073, $6,045, $6,248, and $6,465, and under section 6654(a) of $1,297, $966, $833, and $675, respectively.
After concessions,
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