Memorandum Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's income tax for its fiscal years ending May 31, 1978 and 1979, in the amounts of $8,512,509.00 and $15,169,209.00, respectively. At the time of the filing of the petition, petitioner's principal office was in Santa Clara, California. The Federal tax returns for the years here involved were filed with the Internal Revenue Service, Fresno, California.
On January 17,...
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