MEMORANDUM FINDINGS OF FACT AND OPINION
HAINES, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes for 2001 and 2002 (years at issue) of $39,799 and $21,789, respectively, as well as additions to tax under section 6651(a)(1) of $9,949 and $5,447, and additions to tax under section 6654 of $1,590 and $728, respectively.
The issues for decision are: (1) Whether petitioner failed to report income...
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