MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Judge:
Respondent determined deficiencies in, and penalties on, petitioner David Rothner's (petitioner) Federal income taxes as follows:
Penalty Year Deficiency Sec. 6662(a) 1989 .................. $246,497 $49,299 1990 .................. 88,759 17,752
Respondent also determined...
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