MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Petitioners petitioned the Court to redetermine respondent's determination that they are liable for Federal income tax deficiencies for 1997 and 1998 of $59,117 and $62,558, respectively, and for accuracy-related penalties under section 6662(a) of $11,823.40 and $12,511.60.
We decide the following issues:
1. Whether the trusts petitioners used during 1997 and 1998 should be disregarded...
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