MEMORANDUM FINDINGS OF FACT AND OPINION
LAUBER, Judge.
In these consolidated cases, the Internal Revenue Service (IRS or respondent) determined, against Joel B. Evans (petitioner) for the taxable years 2007 and 2008 and against Joel B. Evans and Donna Evans (petitioners) for the taxable years 2009 and 2010, deficiencies and accuracy-related penalties under section 6662
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