MEMORANDUM OPINION
COHEN, Judge.
Respondent determined deficiencies of $69,576 and $140,594 in petitioner's Federal income taxes for 1996 and 1997, respectively. Respondent also determined that petitioner is liable for a penalty of $13,915 under section 6662 for 1996 and an addition to tax of $35,148 under section 6651(a)(1) for 1997. Petitioner declined to present any evidence at trial, and respondent filed...
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