MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined deficiencies and penalties with regard to petitioners' Federal income tax as follows:
Penalty Year Deficiency I.R.C. Sec. 6663 2000 $106,074 $79,555.50 2001 74,841 56,130.75 2002 74,156 55,617.00
Unless otherwise indicated, all...
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