STERRETT, Judge:
By statutory notice dated December 15, 1978, respondent determined deficiencies in income tax as follows:
Year ended Dec. 31— Deficiency 1971 ------------------------------ $109,701.31 1972 ------------------------------ 11,791.00 1974 ------------------------------ 20,900.50
The years 1971 and 1972 are in issue only because of petitioner's net operating...
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