Memorandum Findings of Fact and Opinion
HAMBLEN, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes as follows:
Taxable Year Ended Deficiency May 31, 1979 .................... $90,724 May 31, 1980 .................... 76,229 May 31, 1981 .................... 76,200
The primary issue for determination is the amount that petitioner is entitled to deduct...
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