MEMORANDUM FINDINGS OF FACT AND OPINION
MARVEL, Judge.
Respondent determined deficiencies in petitioners' Federal income tax of $113,893, $93,581, $144,727, and $149,030 for 2003, 2004, 2005, and 2006, respectively. In the answer respondent asserted that petitioners are liable for accuracy-related penalties under section 6662(a) and (b)(2) and (3)
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