Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
Respondent determined deficiencies in petitioner's income tax as follows:
Tax Year Ended Deficiency 10/31/73 ...................... $493,756 10/31/74 ...................... 157,713 10/31/75 ...................... 811,955 10/31/76 ...................... 348,726
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