Memorandum Findings of Fact and Opinion
CLAPP, Judge:
Respondent determined a deficiency in petitioner's income tax for the year ending November 30, 1987, in the amount of $143,979. Respondent also determined additions to tax under section 6653(a)(1)(A) in the amount of $7,198.95, and section 6653(a)(1)(B) in the amount of 50 percent of the interest due on $143,979. All section references are to the Internal Revenue Code as in effect for the year in issue...
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