Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $3,028,541.49 in petitioner's Federal income tax for 1981 and additions to tax under sections 6651(a)(1), 6653(a)(1), and 6653(a)(2) of $757,135.00, $151,463.00, and 50 percent of the interest due on the entire deficiency, respectively. After concessions, the issues for decision are whether petitioner underreported his gross income for 1981, whether petitioner sustained...
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