MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge:
Respondent determined the following deficiencies in, addition to, and accuracy-related penalties on petitioners' Federal income taxes:
Addition to Tax Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1997 $17,091 $3,956 $3,418 1998 17,867 ...
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