Memorandum Findings of Fact and Opinion
TANNENWALD, Chief Judge:
Respondent determined the following deficiencies in petitioner's Federal income taxes:
Taxable year ended Deficiency October 31, 1973 ....... $ 80,766.51 October 31, 1974 ....... 138,203.51 October 31, 1975 ....... 83,193.72
We must determine whether during the taxable year ended October 31, 1973, petitioner had gross receipts more than 20 percent...
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