MEMORANDUM FINDINGS OF FACT AND OPINION
KERRIGAN, Judge.
Respondent determined deficiencies of $3,223 and $5,025 and accuracy-related penalties under section 6662(a) of $645 and $1,005 for petitioner's tax years 2010 and 2011, respectively.
Unless otherwise indicated, all section references are to the Internal Revenue Code (Code) in effect for the tax years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. We...
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