United States Tax Court.
MEMORANDUM FINDINGS OF FACT AND OPINION
WHALEN, Judge:
Respondent determined the following deficiency in, and penalty on, petitioners' Federal income tax for 1989:
Deficiency Sec. 6662 Penalty $296,702 $59,340
Unless stated otherwise, all section references are to the Internal Revenue Code as in effect for 1989. After concessions, the issues remaining for decision are: (1) Whether the fair market value...
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