MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge:
Respondent determined deficiencies in petitioner's Federal income tax for taxable years 1989 and 1990 of $111,613 and $775, respectively. Respondent also determined a section 6661 addition to petitioner's tax of $27,903 for taxable year 1989. All section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and...
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