Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
By statutory notice dated December 20, 1982, respondent determined deficiencies in petitioner's Federal income tax as follows:
Year Deficiency 1975 ......................... $ 1,899,880 1976 ......................... 84,088 1977 ......................... 36,741,206 1978 ......................... 15,844,349 1979 ..............
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