JACOBS, Judge:
Respondent determined a deficiency of $786,599, and an addition to tax under section 6661 in the amount of $196,650, in petitioners' 1985 Federal income tax, based on the imposition of the golden parachute payments excise tax under section 4999. (Pursuant to section 4999(c)(2), the golden parachute payments excise tax is treated for tax assessment and collection purposes as an income tax.) Respondent now concedes the section 6661 addition to...
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