MEMORANDUM FINDINGS OF FACT AND OPINION
KERRIGAN, Judge.
Respondent determined deficiencies of $42,606 and $38,157 in petitioner's Federal income tax for 2010 and 2011, respectively. Respondent also determined accuracy-related penalties under section 6662(a) of $8,418 and $7,631 for 2010 and 2011, respectively.
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