WILLIAMS, Judge:
These consolidated cases are before the Court on the parties' cross-motions for partial summary judgment pursuant to Rule 121, Tax Court Rules of Practice and Procedure.
The Commissioner determined deficiencies in Federal income tax for petitioner's taxable years ended January 31 of 1972, 1973, 1974, 1975, and 1976 and the short taxable year ended July 1, 1976, as follows:
Docket No....
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