MEMORANDUM OPINION
SWIFT, Judge:
Respondent determined a deficiency of $174,822 in petitioner's Federal income tax for 1988 and additions to tax under sections 6653(a)(1) and 6661 in the amounts of $8,741 and $43,706, respectively.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 1988, and all Rule references are to the Tax Court Rules of Practice and Procedure.
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