Memorandum Findings of Fact and Opinion
COLVIN, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes for the years 1986, 1987, and 1988, in the following amounts:
Year Deficiency 1986 ...................... $156,316.50 1987 ...................... 102,963.55 1988 ...................... 42,145.12
The issue for decision is whether petitioner operated his...
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