Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent determined a deficiency in petitioner's 1983 Federal income tax in the amount of $1,819,310.95, and additions to tax as follows:
Sec. 6651(a)(1)1 Sec. 6653(a)(1) Sec. 6653(a)(2) Sec. 6654 --------------- --------------- --------------- ---------- $454,827.75 $90,965.55 * $111...
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