MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined a deficiency of $310,670 in petitioner's Federal income tax for 1988 and additions to tax of $77,667 under section 6651(a)(1) and $15,749 under section 6653(a)(1). The issues for decision are whether funds received by petitioner in 1988 constituted taxable income and whether petitioner is liable for the additions to tax determined by respondent. Unless otherwise indicated, all section...
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