Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent determined deficiencies in income taxes due from petitioner as follows:
Year Deficiency 1957 ............ $11,100,174.68 1958 ............ $10,272,076.07 1959 ............ $ 9,884,214.27 1960 ............ $16,814,959.53
By agreement of the parties the only issue for decision at this time relates to the question whether there should...
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