MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined deficiencies in petitioners' Federal income tax and penalties as follows:
Year Deficiency Sec. 6662 Penalties Sec. 6663 1999 $3,456 $691.20 -- 2000 46,341 4,094.601 19,401 2001 3566 713.15 ...
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