MEMORANDUM FINDINGS OF FACT AND OPINION
THORNTON, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes as follows:
Taxable year Deficiency 1993 ............................. $712,570 1994 ............................. 436,295 1995 ............................. 380,570
The sole issue for decision is what portion of petitioner's reserves for unpaid losses...
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