Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
Respondent determined the following deficiencies in petitioner's Federal income tax:
Year Deficiency 1975 ......................... $ 3,842,229.12 1976 ......................... 14,706,626.78 1977 ......................... 31,148,144.82 1978 ......................... 45,755...
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