PARR, Judge:
By separate statutory notices, respondent determined deficiencies in petitioners' Federal income tax for the years ending October 31, 1976 (1976), and October 31, 1977 (1977), in the amounts of $673,545.64 and $469,209, respectively. The parties have stipulated that these amounts were determined in error, and that the correct deficiencies for 1976 and 1977 are $672,173 and $554,043, respectively. For convenience, we refer hereinafter to petitioners...
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