MEMORANDUM FINDINGS OF FACT AND OPINION
THORNTON, Judge:
Respondent determined a $1,194,503 deficiency in petitioners' 1993 Federal income tax and a $238,901 accuracy-related penalty pursuant to section 6662(a).
The issues for decision are: (1) Whether the notice of deficiency is entitled to a presumption of correctness; (2) whether petitioners had ordinary unreported income due to forgiveness of indebtedness as determined...
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