MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Petitioner petitioned the Court to redetermine respondent's determinations as to petitioner's 1997, 1998, and 1999 Federal income taxes. Respondent determined for those respective years that petitioner had deficiencies of $36,861, $89,210, and $71,454 and was liable for section 6662(a) accuracy-related penalties of $7,372, $17,842, and $14,291.
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