Memorandum Findings of Fact and Opinion
BEGHE, Judge:
Respondent determined deficiencies in petitioner's 1980 and 1981 Federal income tax in the respective amounts of $251,582 and $1,342,616. The parties have settled all issues relating to petitioner's 1980 taxable year; after concessions by the parties, the issues for decision with respect to petitioner's 1981 taxable year are:
(1) Whether Valero Energy Corp. (Valero) overstated its 1984 net operating...
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