SWIFT, Judge:
Respondent determined a deficiency of $123,855 and an addition to tax and a penalty with respect to petitioner's Federal income tax for 1994.
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.
After settlement of some issues, the primary issue for decision is whether direct transfer of...
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