Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent, by means of a statutory notice of deficiency, determined Federal income tax deficiencies for petitioner's 1984 and 1985 taxable years in the amounts of $2,371,664 and $21,828,460, respectively. On March 11, 1992, the Court ordered separate trials for the domestic and foreign issues. After concessions, the only remaining domestic issue for our consideration is the amount, if any, of the amortization...
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