MEMORANDUM FINDINGS OF FACT AND OPINION
JACOBS, Judge:
Leonard Pipeline Contractors, Ltd. petitioned the Court to redetermine respondent's determination of an $807,983 deficiency in its income tax for its taxable year ended September 30, 1987, and additions to tax pursuant to section 6653(a)(1)(A) in the amount of $40,399 and section 6653(a)(1)(B) in the amount of 50 percent of the interest on $807,983. The deficiency is based on respondent's determination...
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