MEMORANDUM OPINION
PAJAK, Special Trial Judge:
This matter is before the Court on respondent's motion for partial summary judgment.
For the year 1987, respondent determined a deficiency in petitioner's Federal income tax in the amount of $370,360 and additions to tax under section 6653(b)(1)(A) in the amount of $277,770, under section 6653(b)(1)(B) in an amount to be determined of 50 percent of the interest due on $370,360, and under section 6654...
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