Memorandum Findings of Fact and Opinion
COLVIN, Judge:
Respondent determined deficiencies in the amounts of $818,321 for the taxable year ending September 25, 1977, $4,295,583 for the taxable year ending September 24, 1978, and $196,863 for the taxable year ending September 27, 1981. Petitioner has conceded all adjustments contained in the statutory notice of deficiency with the exception of the foreign tax credit adjustment made pursuant to section 904...
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