MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined a deficiency of $177,929 in petitioner's Federal income tax for 1996 and a penalty of $35,445 under section 6662(a). After concessions by respondent, the amounts remaining in dispute are a deficiency of approximately $40,000 and a penalty of approximately $8,000. The issue for decision is whether petitioner is entitled to any deductions beyond those conceded by respondent. Unless...
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