Memorandum Findings of Facts and Opinion
CLAPP, Judge:
Respondent determined a deficiency in and additions to petitioner's 1986 Federal income tax as follows:
Additions to tax under section ---------------------------------------- Deficiency 6653(b)(1)(A) 6653(b)(1)(B) 6661 $2,568,768 $1,926,576 * $642,192 * 50 percent of the interest due on...
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