Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $2,559,639.13 in petitioner's Federal income tax for 1987 and additions to tax of $127,981.96 under section 6653(a)(1)(A), 50 percent of the interest due on $2,559,639.13 under section 6653(a)(1)(B), and $639,909.78 under section 6661(a). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule...
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