OPINION
HALPERN, Judge:
By notice of deficiency dated December 22, 2005, respondent determined deficiencies in petitioners' Federal income taxes of $203,939 and $70,815 for 2001 and 2002, respectively, and accuracy-related penalties of $40,788 and $14,163 for those years, respectively.
Unless otherwise indicated, all section references are to the Internal Revenue Code for the years at issue, and all Rule references are to the Tax Court Rules...
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