Respondent determined Federal income tax deficiencies in petitioner's taxable income of $4,904,470 and $14,143,945 for the taxable years ending March 31, 1982, and March 31, 1983, respectively. The deficiencies are solely attributable to respondent's determination that petitioner did not qualify as a domestic international sales corporation (DISC).
The major issue for consideration is the validity...
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