MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge:
In Docket No. 16379-94, respondent determined a deficiency in L.L. Bean, Inc.'s (hereinafter petitioner) 1986 Federal income tax of $649,428. In Docket No. 16380-94, respondent issued a notice of final S corporation administrative adjustment (FSAA) to Leon Gorman, petitioner's president and tax matters person, setting forth the following disputed adjustments with respect to petitioner's 1987 taxable year...
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