Memorandum Findings of Fact and Opinion
STERRETT, Judge:
The respondent determined the following deficiencies in petitioner's federal income tax for the following fiscal years ended March 31:
Docket No. Year Deficiency 2380-71 1966 ........... $19,863,00 1967 ........... 4,515.00 8964-72 1969 ........... 4,839.89
The principal issue is whether the three tracts of real estate owned...
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