OPINION
RUWE, Judge:
Petitioner is a corporation organized and existing under the laws of the State of California. At the time the petition was filed, petitioner had its principal office at 14711 Bentley Circle, Tustin, California.
On July 3, 1985, respondent mailed a notice of deficiency to petitioner determining deficiencies and an addition to tax as follows:
TYE ...
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