Memorandum Findings of Fact and Opinion
STERRETT, Chief Judge:
By notice of deficiency dated December 4, 1981, respondent determined deficiencies in petitioner's Federal income taxes as follows:
Tax Year Ended Deficiency 9/30/72 ................. $ 546,278 9/30/73 ................. 931,546 9/30/74 ................. 292,313 9/30/75 ................. 1,321,821 ...
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