MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge.
Respondent determined deficiencies and penalties with respect to petitioners' Federal income tax as follows:
Year Deficiency Penalty I.R.C. sec. 6662 2002 $58,816 $11,763.20 2003 95,217 19,043.40 2004 87,442 17,488.40
Unless otherwise indicated, all section references are...
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