Memorandum Findings of Fact and Opinion
COLVIN, Judge.
Respondent determined that petitioner has an income tax deficiency of $49,287.49 for 1987. Respondent also determined that petitioner is liable for additions to tax for fraud under section 6653(b)(1)(A) and (B) and substantial understatement of tax under section 6661 for 1987. Respondent concedes the addition to tax for fraud.
After concessions, the issues for decision are:
1. Whether...
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