MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge:
Respondent determined deficiencies in petitioner's Federal income tax for 1988 and 1989 of $482 and $213,139, respectively. By amended answer, respondent asserted increased deficiencies for 1988 and 1989 of $78,277 and $31,929, respectively. Thus, the total deficiencies asserted by respondent for 1988 and 1989 are $78,759 and $245,068, respectively.
All section references are to the Internal Revenue...
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