MEMORANDUM FINDINGS OF FACT AND OPINION
WHALEN, Judge:
Respondent determined the following deficiencies in, and penalties with respect to, petitioners' Federal income tax for 1999 and 2000:
Additions to Tax/Penalties Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 2000 1,000.00 None None 1999 $94,699.32 $23,674.83 ...
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