Memorandum Findings of Fact and Opinion
COLVIN, Judge:
Respondent determined a deficiency of $20,906 for taxable year 1987, and additions to tax for negligence of $1,045 under section 6653(a)(1)(A) and 50 percent of the interest due on $20,906 under section 6653(a)(1)(B), and for substantial understatement of tax of $5,227 under section 6661. The issues for decision are:
(1) Whether $77,738 in payments received by petitioner from a partnership was...
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