MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined that petitioner had an income tax deficiency of $397,590 for 1984 and additions to tax of $198,795 under section 6653(b)(1) and $99,398 under section 6661(a). Respondent also determined that petitioner was liable for the addition to tax under section 6653(b)(2) of 50 percent of the interest payable on the entire deficiency.
Petitioner was a certified public accountant in...
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