MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge:
By notice of deficiency dated May 22, 1996, respondent determined a $4,834,273 deficiency in petitioner's 1989 Federal income tax, a $178,587 accuracy-related penalty, and a $2,956,005 fraud penalty.
Respondent has conceded the fraud penalty. The issues remaining for decision are: (1) Whether the period of limitations on assessment and collection of petitioner's income tax liability for 1989...
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