Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes for the taxable year ended November 30, 1960, in the amount of $162,399.83; for the taxable period December 1 to December 31, 1960, in the amount of $11,050.24; and for the calendar year 1961 in the amount of $121,522.70. Petitioner's taxable year ended November 30, 1959, is also in dispute because of a disallowed net operating loss...
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