Memorandum Findings of Fact and Opinion
PARKER, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1981 in the amount of $489,629 and an addition to tax under section 6653(b) in the amount of $246,819.
Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and in effect for the taxable year in question, and all rule references are to the Tax Court Rules of Practice...
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