COLVIN, Judge:
Respondent determined deficiencies in petitioners' Federal income tax of $75,293 for 1973, $244,229 for 1974, $4,234,380 for 1975, $124,345 for 1976, $72,325 for 1977, and $95,160 for 1978.
Following concessions, a conditional settlement of various issues, and our opinion in Estate of Durkin v. Commissioner,
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