MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes of $24,295 for 1993 and $27,893 for 1994, and accuracy-related penalties under section 6662(a) for negligence of $4,859 for 1993 and $5,578 for 1994.
In 1993, petitioner transferred his residence and medical practice to the Arivada Health Enterprises Trust (Arivada). Respondent determined that Arivada is a sham and lacks...
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