MEMORANDUM FINDINGS OF FACT AND OPINION
WRIGHT, Judge:
Respondent determined a deficiency of $133,906 in petitioner's Federal income tax and an accuracy-related penalty under section 6662(a) of $26,781 for the taxable year ending May 31, 1991.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
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