Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined a deficiency in petitioner's 1980 income tax of $33,746.35 and an addition to tax pursuant to section 6653(a) of $1,376.50. After concessions, the issues remaining for decision are (1) whether petitioner or Ampere Electric Company (Ampere), his wholly-owned corporation, is taxable on income received in 1980 from a pyramid scheme; (2) whether petitioner or Ampere was a partner in...
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