MEMORANDUM OPINION
WHALEN, Judge:
Respondent determined the following deficiencies in petitioner's Federal income tax:
Year Deficiency 1979 $10,563,157 1981 5,163,449 1983 35,916,359
Petitioner disputes the above deficiencies and further claims to have overpaid income taxes for 1979, 1981, and 1983 by at least $25...
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