WILLIAMS, Judge:
In these consolidated cases, the Commissioner determined deficiencies in petitioners' Federal corporate income tax for the taxable years 1979, 1981, and 1982 as follows:
Docket No. Year Deficiency 30292-85 1979 $30,693,922 37799-85 1981 29,618,171 47753-86 1982 1,130,372
The sole issue remaining for our decision is whether petitioners are entitled to percentage...
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