MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Respondent determined a deficiency in petitioner's 1989 corporate Federal income tax of $218,015 and an addition to tax under section 6651(a)(1) of $66,778.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 1989, and all Rule references are to the Tax Court Rules of Practice and Procedure.
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