Memorandum Opinion
COHEN, Judge:
Respondent determined a deficiency of $250,241.00 in petitioner's Federal income tax for 1985 and additions to tax of $62,260.75 under section 6651(a)(1), $12,512.05 under section 6653(a)(1), 50 percent of the interest due on $249,043.00 under section 6653(a)(2), and $62,261.00 under section 6661. Unless otherwise indicated, all section references are to the Internal Revenue Code as amended and in effect for the year in issue...
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