MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge:
Respondent determined a $741,379 deficiency in petitioner's Federal income tax for tax year ended June 30, 1991, a $37,068.95 section 6651(a)(1) addition to tax, and a $148,275.80 section 6662(a) accuracy-related penalty.
Following concessions by petitioner,
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