MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
This is a proceeding for redetermination of a deficiency in income tax and penalties for petitioner's 1995 tax year, as set forth below:
Year Deficiency Sec. 6662 Penalty 1995 ................. $70,198 $14,040
After concessions,
(1) Whether a deduction...
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