OPINION
STERRETT, Judge:
By notice of deficiency dated May 26, 1977, respondent determined deficiencies in petitioner's Federal income taxes as follows:
TYE July 31— Deficiency 1973 ............... $19,010.32 1974 ............... 29,941.97 1975 ............... 235,130.00
After concessions, the sole issue...
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