MEMORANDUM FINDINGS OF FACT AND OPINION
WHALEN, Judge:
Respondent determined the following deficiency in, and addition to, petitioners' 1989 income tax:
Addition to Tax Deficiency Sec. 6651(a)(1) $254,336.56 ...................... $65,880.58
All section references are to the Internal Revenue Code, as in effect during 1989. References to petitioner...
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