Memorandum Findings of Fact and Opinion
SCHIELDS, Judge:
Respondent determined deficiencies in petitioner's income taxes as follows:
Fiscal Year Ended Deficiency October 31, 1974 .............. $ 11,431.22 October 31, 1975 .............. $ 28,027.30 October 31, 1977 .............. $ 63,138.28 October 31, 1978 .............. $ 4,035.98 October 31, 1979 .............. $ 51,617.28
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