MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Stephen D. Ruddel petitioned the Court to redetermine respondent's determination of a $130,764 deficiency in his 1987 Federal income tax and a $32,691 addition thereto under section 6651(a)(1). Respondent reflected this determination in a notice of deficiency issued to petitioner on August 22, 1994.
Following concessions, we must decide:
1. Whether petitioner may deduct certain payments...
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