MEMORANDUM FINDINGS OF FACT AND OPINION
HAINES, Judge.
Respondent determined deficiencies in petitioner's Federal income taxes for 1999, 2000, and 2001 (years at issue) of $1,517,634, $3,859,291, and $1,737,726, as well as additions to tax under section 6651(a)(1) of $379,409, $868,340, and $434,432, respectively, and additions to tax for 2000 under section 6651(a)(2) of $964,823, and under section 6654(a) of $206,144.
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