MEMORANDUM OPINION
GOEKE, Judge:
Respondent determined income tax deficiencies against petitioner for 1998, 1999, and 2000 in the amounts of $172,626, $31,059, and $222,655, respectively. Respondent also determined additions to tax under section 6651(a)(1) for 1998, 1999, and 2000 in the amounts of $30,602.25, $7,810.50, and $55,663.75, respectively.
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