MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Judge:
Respondent determined a deficiency of $9,460,419 in the Federal income tax of petitioner Computervision International Corp. (CVI) for its taxable year ended January 31, 1984.
Respondent determined the following deficiencies in the Federal income tax of petitioners Computervision Corp. (CV) and subsidiaries for the following years:
Taxable Year Ended Deficiency...
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