OPINION
VASQUEZ, Judge:
Petitioners move the Court to dismiss this case for lack of jurisdiction. Petitioners petitioned the Court to redetermine respondent's determination of a $1,581,293 deficiency in petitioners' Federal income tax for 1999 and a $632,517 accuracy-related penalty under section 6662(h) (or alternatively a lesser accuracy-related penalty under section 6662(a)).
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