MEMORANDUM FINDINGS OF FACT AND OPINION
WHALEN, Judge:
Respondent determined the following deficiency and penalties with respect to petitioner's 1990 taxable year:
Penalties --------------------------- Deficiency Sec. 6662(a) Sec. 6663(a) $1,530,128 ............ $303,025.86 $32,726.25
All section references are to...
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