Memorandum Findings of Fact and Opinion
COLVIN, Judge:
Respondent determined a $225,337 deficiency in petitioner's 1982 income tax. Respondent also determined additions to tax for 1982 of $11,267 for negligence under section 6653(a)(1), 50 percent of the interest due on the underpayment under section 6653(a)(2), and $56,334 for substantial understatement of income tax under section 6661.
The sole issue for decision is whether petitioner qualifies...
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