Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent, in a statutory notice of deficiency dated December 21, 1984, determined deficiencies in petitioner's Federal income taxes of $702,487 and $25,877 for the taxable years ended March 31, 1981, and March 31, 1982, respectively, and an addition under section 6651(a)
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