MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes of $58,283 for 1996 and $59,226 for 1997, an addition to tax under section 6651(a)(1) of $14,794.25 for 1997, and accuracy-related penalties under section 6662(a) of $11,656.60 for
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