Memorandum Findings of Fact and Opinion
IRWIN, Judge:
The Commissioner determined the following deficiencies in petitioner's income tax:
Year Deficiency 1964 ........... $ 65,800.74 1965 ........... 80,412.05 ___________ Total ........ $146,212.79
Nearly all of these amounts are in controversy as a result of respondent's determination that the principal purpose of petitioner's...
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