MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Chief Judge:
Respondent determined deficiencies in, and penalties on, petitioner's Federal income taxes as follows:
Year Deficiency Sec. 6653(a) 1990 ....... $416,765.00 $312,573.75 1991 ....... $370,588.00 $277,941.00
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and...
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