Memorandum Findings of Fact and Opinion
QUEALY, Judge:
Respondent determined deficiencies in the corporate income tax of petitioners for the taxable years 1958, 1959, and 1960 in the amounts of $2,999,814.47, $961,172.31 and $3,779,364.60, respectively.
Due to concessions by the parties, the only questions that remain for this Court's determination relate to Compania Exploradora del Istmo, S.A. (hereinafter referred to as "CEDI"), a wholly-owned...
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