SWIFT, Judge:
By notice of deficiency dated June 11, 1981, respondent determined deficiencies in petitioner's Federal income tax liabilities for the years 1975 and 1976 in the total amount of $2,052,613 ($1,479,982 for 1975 and $572,631 for 1976). In its timely filed petition, petitioner disputed $1,967,757 of the total deficiencies for both years, and petitioner also claimed refunds in the total amount of $3,226,786. By amendment to its petition, petitioner...
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