JACOBS, Judge:
Pursuant to two notices of deficiency addressed to petitioner, respondent determined Federal income tax deficiencies and an overpayment, as follows:
TYE June 30 Deficiency Overpayment 1987 $6,279,330 - - - 1988 4,618,862 - - - 1989 1,644,505 - - - 1990 - - - $1,944...
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