MEMORANDUM OPINION
RUWE, Judge.
Respondent determined the following deficiencies in petitioner's Federal income taxes:
TYE Deficiency July 31, 1995 ....................... $132,164 July 31, 1996 ....................... 123,604 Dec. 31, 1996 ....................... 52,851
After taking into consideration the agreed adjustments contained in the notice of deficiency for the years...
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