MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge.
Respondent determined a deficiency of $463,386 in petitioner's Federal income tax for 1998 and additions to tax under section 6651(a)(1) for failure to timely file of $112,138 and under section 6654(a) for failure to pay estimated tax of $20,449.58.
After concessions, the issues for decision are:
1. Whether the notice of deficiency was arbitrary. We hold that it was not.
2. Whether...
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