United States Tax Court.
MEMORANDUM FINDINGS OF FACT AND OPINION
GALE, Judge:
Respondent determined a deficiency of $405,017, and an accuracy-related penalty under section 6662(a) in the amount of $81,003.40, for petitioner's 1992 taxable year. Unless otherwise noted, all section references are to the Internal Revenue Code in effect for the year in issue.
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