Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $186,560 in petitioner's Federal income tax for 1981 and additions to tax under section 6653(a)(1), section 6653(a)(2), and section 6654(a). Unless otherwise indicated, all section references are to the Internal Revenue Code as amended and in effect for the year in issue.
The issues for decision are (1) whether evidence obtained by local police officers, without...
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