SWIFT, Judge:
Respondent determined deficiencies in petitioner's consolidated Federal income tax as follows:
Year Deficiency 1982 ......................... $ 196,095 1983 ......................... $5,084,075 1984 ......................... $3,916,678 1985 ......................... $ 608,021
After settlement of some issues, the issue for decision is whether Utah Power & Light Co. ...
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