Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined deficiencies in, and additions to, petitioner's Federal income taxes as follows:
Addition to Tax Year Deficiency Sec. 6653(a)1 1979 .......... $1,102,877.70 $54,909.04 1980 .......... 34,486.97 4,160.63
Respondent having...
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