Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
The Commissioner determined deficiencies in the petitioner's Federal income taxes, and the petitioner claimed an overpayment of tax, as follows:
Year Deficiency Overpayment 1970 ........... $172,492.76 $48,263.00 1971 ........... 204,827.88 -0- 1972 ........... 451,303.79 -0-
The issues remaining for decision are: (1) Whether the Commissioner...
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