Memorandum Findings of Fact and Opinion
JACOBS, Judge:
Respondent determined a deficiency in petitioners' 1979 Federal income tax in the amount of $1,164,556 and an addition to tax pursuant to section 6653(b) in the amount of $582,278.
After concessions, the issues for decision are:
(1) Whether petitioner Aaron A. Kleinman (Mr. Kleinman) received unreported income of $1,225,448 for tax year 1979. We hold that he received unreported income...
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