Memorandum Findings of Fact and Opinion
WILLIAMS, Judge:
The Commissioner determined deficiencies in petitioner's Federal income tax as follows:
Taxable year ending: Deficiency June 30, 1980 ................... $181,403 June 30, 1981 ................... 474,729 June 30, 1982 ................... 132,640
Petitioner has claimed overpayments for each of the years....
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