MARVEL, Judge:
Respondent determined the following deficiencies in the Federal income tax of Merrill Lynch & Co., Inc. (Merrill Parent), & Subsidiaries (collectively, the consolidated group or petitioner):
TYE Deficiency Dec. 26, 1986 .............................. $7,704,908 Dec. 25, 1987 .............................. 12,141,242 Dec. 30, 1988 ............................
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