MEMORANDUM FINDINGS OF FACT AND OPINION
BEGHE, Judge:
Respondent determined a deficiency in petitioner's Federal income tax and an addition to tax and a penalty as follows:
Addition to tax Penalty Year Deficiency Sec. 6651(a)(1)1 Sec. 6662 1989 $75,389 $3,769.45 $150,077.80
Following concessions by the parties...
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