MEMORANDUM OPINION
COHEN, Judge.
Respondent determined deficiencies of $66,470 and $90,777 in petitioner's Federal income taxes for 1996 and 1997, respectively, and determined penalties under section 6662 of $13,294 and $18,155 for those years, respectively. The issues for decision are whether petitioner had unreported income for services rendered as an osteopathic physician or as a homeopathic physician, whether the Court has jurisdiction to make that determination...
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