Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined a deficiency in petitioner's Federal income tax and additions to tax pursuant to section 6653(b)
Taxable Addition to tax Year Deficiency (sec. 6653(b)) 1968 ............. $400,046 $200,023
The issues for decision are: (1) whether petitioner understated...
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