NIMS, Judge:
Respondent determined deficiencies in Federal income tax with respect to petitioner's fiscal year ended June 30, 1986 (FYE 1986), in the amount of $6,466,674.82, and with respect to petitioner's fiscal year ended June 30, 1987 (FYE 1987), in the amount of $11,493,459. In addition to contesting these deficiencies, petitioner claims overpayments in Federal income tax with respect to FYE 1986 in the amount of $4,760,484 and with respect to FYE 1987...
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