Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes for the calendar years 1975 and 1977 in the amounts of $1,052,741 and $86,544, respectively. All issues for the year 1977 having been settled between the parties, we must determine whether or not petitioner is taxable for the year 1975 on $1,384,407 of foreign personal holding company income and whether petitioner omitted an additional...
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