MEMORANDUM FINDINGS OF FACT AND OPINION
VASQUEZ, Judge:
Respondent determined deficiencies and penalties with respect to petitioner's 1999, 2000, and 2001 Federal income tax as follows:
Penalties Year Deficiency Sec. 6662(a)1 Sec. 6663 1999 $45,969.00 $2,434.20 $25,348.50 2000 42,401.00 ...
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