RUWE, Judge:
Respondent determined deficiencies in petitioner's Federal income tax in the amounts of $1,107,505 and $40,192 for the taxable periods ending August 31, 1985, and August 31, 1986, respectively.
After concessions, the issues for decision are: (1) Whether the $292,617 received by petitioner pursuant to its service contract with Landmark, Inc., during the taxable year ending August 31, 1985, constituted unrelated business taxable income; ...
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