KÖRNER, Judge:
By statutory notice of deficiency dated July 10, 1991, respondent determined deficiencies in the Federal income tax of Phillips Petroleum Co. and its affiliated subsidiaries (hereinafter Phillips or petitioners) for the taxable years 1979 through 1982 as follows:
Year Deficiency 1979 ............................ $59,029,820 1980 ............................ 61...
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