Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined deficiencies in petitioner's income tax as follows:
Fiscal Year Ended Deficiency September 30, 1961 .......... $ 99,449.35 September 29, 1962 .......... 269,098.98 September 28, 1963 .......... 95,469.17
We must decide whether, for each of the taxable years in question, petitioner was availed of for the purpose...
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