MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
Respondent determined deficiencies in petitioner's income tax of $173,261 for its taxable year ending October 31, 1990, and $123,873 for its taxable year ending October 31, 1992.
Petitioner sold seeds, fertilizer, and other supplies to farmers during the years in issue. Petitioner's owner provided advice and some financial assistance to petitioner's customers. The...
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