MEMORANDUM OPINION
HAMBLEN, Chief Judge:
Respondent determined a deficiency of $191,895.19 in petitioner's 1983 Federal income tax and an addition to tax of $9,594.76 under section 6653(a)(1). Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the taxable year at issue, and Rule references are to the Tax Court Rules of Practice and Procedure.
This case is before the Court on petitioner's motion for summary...
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