United States Tax Court.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined that petitioner has a deficiency in Federal income tax of $111,795 for 1990 and additions to tax of $27,706 under section 6651(a)(1) and $797 under section 6654. Petitioner was president of Elan Leather Corp. (Elan). After concessions, we must decide the following:
1. With respect to $146,193 of Elan's income that petitioner...
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