MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge:
Respondent determined a deficiency in the amount of $132,675 in petitioner's Federal income tax for 1988 and an addition to tax pursuant to section 6653(b)(1) in the amount of $101,783. Respondent asserted the delinquency and negligence additions to tax under sections 6651(a)(1) and 6653(a)(1), respectively, in the alternative to the fraud addition to tax. Unless otherwise noted, all section references...
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