Memorandum Opinion
SCOTT, Judge:
Respondent determined deficiencies in the income tax of Tele-Communications, Inc., and Subsidiaries (TCI) for the calendar years 1979, 1980, and 1981, and determined a deficiency in the income tax of TCI Development Corporation, Successor to Tele-Communications Investments, Inc., and Subsidiaries (TCII) for the calendar year 1980, and determined deficiencies in the income tax of Athena Communications Corporation and Subsidiaries...
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