SIMPSON, Judge:
The Commissioner determined the following deficiencies in the petitioner's Federal income taxes:
Taxable year ended Deficiency Oct. 31, 1974 ...................... $601,634.68 Oct. 31, 1977 ...................... 1,399,920.00 Oct. 2, 1978 ...................... 452,058.00
After concessions by the parties, the issues remaining for decision are: (1) Whether the petitioner...
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