Memorandum Findings of Fact and Opinion
Respondent determined deficiencies in petitioner's federal income taxes for fiscal years ended November 30, 1958 through November 30, 1963, in the total amount of $399,029.69. By reason of petitioner's concessions with regard to certain minor matters involved in respondent's determination of deficiencies the issues now before us for adjudication have been reduced and the parties have stipulated that: