Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
In two separate notices of deficiency, respondent determined deficiencies in petitioner's income tax for the taxable years and in the amounts shown below:
Year Amount 1976 .............. $156,531 1977 .............. 245,576 1978 .............. 123,155 1979 .............. 106,628
Petitioner filed...
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