MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined that the Estate of Robert E. Cartwright (petitioner) had a deficiency in Federal income tax of $1,142,472 for 1988.
Robert E. Cartwright (decedent) owned 71.43 percent of the stock of the law firm of Cartwright, Slobodin, Bokelman, Borowsky,
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