JACOBS, Judge:
Respondent determined deficiencies in petitioner's Federal income taxes as follows:
TYE Deficiency June 26, 1993 ............................... $432,619 Dec. 31, 1993 ............................... 432,619 Dec. 31, 1994 ............................... 432,619 Dec. 31, 1995 ............................... 432,619
These deficiencies...
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