Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined a deficiency in petitioner's Federal income tax for the taxable year ended August 1, 1968, in the amount of $196,246.47. The issues presented for decision are as follows:
(1) Whether respondent is estopped from reopening petitioner's case for the taxable year ended August 1, 1968, after it was closed in accordance with an agreement reached at a district conference;...
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