Memorandum Opinion
HALPERN, Judge:
By notice of deficiency dated February 11, 1991, respondent determined deficiencies in petitioner's Federal income tax liabilities for petitioner's taxable years ended September 30, 1985, 1986, and 1987, in the amounts of $12,654, $22,591, and $152,514, respectively. In its petition, petitioner assigned error to respondent's determinations that (1) income from petitioner's rental of its mailing lists constituted unrelated...
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