MEMORANDUM FINDINGS OF FACT AND OPINION
WHALEN, Judge:
Respondent determined the following deficiencies in petitioner's income tax for the years in issue:
Year Ended Deficiency August 31, 1982 ................ $ 402,453 August 31, 1983 ................ 32,312,944 August 31, 1984 ................ 38,037,781 August 31, 1986 ................ 21,569
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