CURTIS v. COMMISSIONER

Memorandum Findings of Fact and Opinion

RUWE, Judge:

Respondent determined a deficiency in petitioner's 1983 Federal income tax and additions to tax as follows:

                                       Additions to Tax
Deficiency      Sec. 6653(b)(1)1        Sec. 6653(b)(2)          Sec. 6654

                                   50 percent of the interest
$3,645,464        $1,822...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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