Memorandum Opinion
HAMBLEN, Judge:
Respondent determined the following deficiencies in petitioners' income tax returns for 1979 and 1980 (hereinafter sometimes referred to as the years in controversy):
Year Amount of Deficiency 1979 ........................ $13,674,981 1980 ........................ 28,541,936
Respondent also determined that petitioners are liable for increased...
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