MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge:
Respondent determined a deficiency in petitioner Larry Wade Human's Federal income tax for his 1992 taxable year in the amount of $272,222. Respondent further determined that petitioner is liable for an accuracy-related penalty for negligence or disregard of rules or regulations pursuant to section 6662(a) in the amount of $54,444 for that year.
Unless otherwise indicated, all section references...
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