MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Petitioner petitioned the Court to redetermine respondent's determinations as to its taxable years ended August 31, 1998 and 1999. Respondent determined that petitioner is liable for deficiencies of $65,772 and $53,459, respectively. Respondent determined that petitioner is liable for section 6662(a) accuracy-related penalties of $13,154.40 and $10,691.80, respectively.
Following the parties' concessions...
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