MEMORANDUM FINDINGS OF FACT AND OPINION
NEGA, Judge.
Respondent issued a notice of deficiency to Anil V. Shah (Dr. Shah) and Preeti A. Shah (Mrs. Shah) (Shahs, collectively), for tax years 2004 through 2006. Respondent contemporaneously issued Dr. Shah's solely owned corporation — Coastal Heart Medical Group, Inc. (Coastal Heart...
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