MEMORANDUM FINDINGS OF FACT AND OPINION
PARR, Judge:
Respondent determined deficiencies in petitioner's Federal income tax for taxable years 1989 and 1990 of $171,985.68 and $183,196.30, respectively. The issues for decision are: (1) Whether certain payments made by vendors to petitioner are includable in petitioner's income. We hold they are. (2) Whether cash which petitioner supplied to vendors for distribution to petitioner's member stores at petitioner...
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