HAMBLEN, Judge:
Respondent determined deficiencies with respect to the Federal income tax liability of petitioners as follows:
Petitioner Year Deficiency Orange & Rockland Utilities, Inc. 1976 $4,239,516 (O & R) Rockland Electric Co. (Rockland) 1976 2,813 Orange & Rockland Utilities, Inc., 1977 1,651,500 and Subsidiaries (O & R group)...
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