United States Tax Court.
Memorandom Findings of Fact and Opinion
WHALEN, Judge:
Respondent determined a tax deficiency of $379,624 and an addition to tax under section 6653(b)(1) of $189,812 in petitioner's Federal income tax for taxable year ending December 31, 1980. All section references are to the Internal Revenue Code as in effect for that year.
The principal issues for decision are: (1) Whether petitioner realized...
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