Memorandum Findings of Fact and Opinion
WHALEN, Judge:
Respondent determined the following deficiency in and addition to petitioner's Federal income tax for petitioner's taxable year ending February 29, 1984:
Deficiency Sec. 6661(a) $160,124.00 $40,031.00
All section references are to the Internal Revenue Code as amended unless otherwise stated.
By amended answer, respondent asserts the following...
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