Memorandum Opinion
WHITAKER, Judge:
By statutory notice of deficiency dated December 20, 1982, respondent determined deficiencies in petitioner's Federal income tax as follows:
Year Deficiency 1975 ............ $ 1,899,880 1976 ............ 84,088 1977 ............ 36,741,206 1978 ............ 15,844,349 1979 ............ 3,896,519
Pursuant to joint motion, the Brazilian foreign...
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