MEMORANDUM OPINION
TANNENWALD, Judge:
Respondent determined the following deficiencies in petitioner's Federal income taxes and additions to tax:
Additions to Tax Year Deficiency Sec. 6661(a) 1985 ....... $ 117,988.00 -- 1986 ....... 11,630,928.00 $1,429,687.00 1987 ....... 4,924,255.00 --
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