MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge.
By notice of deficiency dated February 2, 2001 (the notice), respondent determined deficiencies in petitioner's Federal income tax as follows:
TYE 6/30 Deficiency 1995 ................ $161,680 1996 ................ 152,933 1997 ................ 61,628
The adjustments...
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