MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined a $203,201 deficiency in petitioner's income tax for 1997.
Petitioner held a 99.5-percent partnership interest in O.M. Cook Co. (OMCC), a partnership engaged in the business of grass seed production. In the notice of deficiency, respondent disallowed (1) a $625,000 deduction that OMCC claimed with regard to the settlement of a lawsuit, and ...
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