BRUCE, Judge:
Respondent determined deficiencies in the petitioner's Federal income taxes for the fiscal years ending (FYE) April 30, 1972, and April 30, 1974, in the amounts of $30,012.24 and $396,337.66, respectively, as set forth in his statutory notice of deficiency dated November 4, 1975. Presented for our decision are (1) whether a sale by petitioner's shareholders of a dividend in kind of navy beans by petitioner will be imputed to petitioner, (2) whether...
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