Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in Federal income taxes of B.T. Fooks, Inc. for its fiscal years ended October 31, 1967, and October 31, 1970, in the amounts of $973.36 and $87,072.51, respectively, and determined a deficiency in Federal income tax of B.T. Fooks and Gulnare Fooks for their calendar year 1970 in the amount of $221,138.22. Certain issues raised by the pleadings were conceded by each...
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