Memorandum Findings of Fact and Opinion
WRIGHT, Judge:
By notice of deficiency dated December 12, 1986, respondent determined the following deficiencies in petitioner's Federal income tax:
Tax Year Ended Deficiency 3/31/78 ............... $ 699,569.00 3/31/81 ............... 1,078,098.00 3/31/82 ............... 306,946.00 3/31/84 ............... 7,703,022.00
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