Memorandum Findings of Fact and Opinion
BRUCE, Judge:
Respondent determined deficiencies in the petitioner's Federal income taxes for the fiscal years ended (FYE) October 31, 1971 and FYE October 31, 1972, of $148,351.92 and $3,456.32, respectively, as set forth in his statutory notice of deficiency dated December 17, 1976. Due to concessions by petitioner,
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