HAMBLEN, Judge:
Respondent determined deficiencies in petitioner's Federal income and branch profits tax for the taxable years 1988, 1989, and 1990, in the amounts of $518,102, $23,730, and $71,662, respectively.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The sole issue for decision is whether...
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