MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
James P. Whitmer petitioned the Court to redetermine respondent's determination with respect to his 1987 and 1988 Federal income taxes. For 1987, respondent determined a $76,005 deficiency, a $3,800 addition to tax under section 6653(a)(1)(A), and a $19,001 addition to tax under section 6661(a). Respondent also determined that petitioner was liable for an addition to tax under section 6653(a)(1)(B). For...
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