MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge:
Respondent has determined a deficiency of $165,366 in petitioner's 1998 Federal income tax liability and an addition to tax of $16,484 for that year on account of petitioner's failure to file her 1998 return on time. Petitioner concedes the addition to tax and two of respondent's adjustments resulting in his determination of a deficiency. Putting aside a computational adjustment that requires no decision...
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