Memorandum Findings of Fact and Opinion
HALPERN, Judge:
By notice of deficiency dated March 21, 1990, respondent determined a deficiency in petitioner's Federal income tax for the tax year ended December 31, 1984, in the amount of $445,986.34, together with an addition to tax in the amount of $111,497. That addition was imposed under section 6661, on account of a substantial understatement of income tax liability. The only issue for decision is whether petitioner...
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