MEMORANDUM FINDINGS OF FACT AND OPINION
MORRISON, Judge.
The respondent (referred to here as the "IRS") issued a notice of deficiency to the petitioner, Richard A. Canatella, for the taxable years 2008, 2009, and 2010. The IRS determined tax deficiencies of $248,262 for 2008, $92,758 for 2009, and $128,167 for 2010, and accuracy-related...
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