Attorney(s) appearing for the Case
B. J. Seery, for the petitioner.1
Ronald M. Rosen, for the respondent.
United States Tax Court.
OPINION
KÖRNER, Judge:2
Respondent determined deficiencies in Federal income taxes for petitioner and certain consolidated subsidiaries for the 1979, 1980, and 1981 taxable years3 as follows:
Taxable year Deficiency
1979 .................................... $2,042,782
1980 ...............
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