OPINION
GOFFE, Judge:
The Commissioner determined a deficiency in petitioner's Federal income tax for the taxable year 1980 in the amount of $2,587,079 and a deficiency in petitioner's Federal income tax for the short taxable year ended April 24, 1981, in the amount of $7,072,671. Respondent claimed an increased deficiency in an amendment to his answer for the short taxable year ended April 24, 1981, in the amount of $4,487,160. The parties have settled...
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